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Thompson Hine LLP, a full-service business law firm with approximately 400 lawyers in 8 offices, was ranked number 1 in the category “Most innovative North American law firms: New working models” by The Financial Times and was 1 of 7 firms shortlisted for The American Lawyer’s inaugural Legal Services Innovation Award. The firm has been recognized by the National Law Journal as a Legal Technology Trailblazer and featured by Bloomberg for its innovative service delivery models, which drive accuracy and predictability. The firm’s commitment to innovation is embodied in Thompson Hine SmartPaTHTM – a smarter way to work – predictable, efficient and aligned with client goals. For more information, please visit ThompsonHine.com and ThompsonHine.com/SmartPaTH.

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On August 28, the U.S. Securities and Exchange Commission (SEC) adopted amendments to reporting requirements for Forms N-PORT and N-CEN and provided guidance on open-end fund liquidity risk management programs.

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The amendments require funds to file monthly Form N-PORT reports within 30 days after the end of each month. Additionally, the amendments will make these reports available to the public 60 days after the end of the month. Since information will be filed with the SEC, funds will no longer be required to maintain records of this monthly information within 30 days of month end.

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The Form N-CEN amendments require funds that are subject to Rule 22e-2 under the Investment Company Act of 1940 to report certain information about service providers used to fulfill liquidity risk management program requirements.

Lastly, the amendments provide guidance on certain open-end fund liquidity risk program requirements to address questions related to the frequency of classifying the liquidity of fund investments; the meaning of “cash” in the liquidity rule; and determining and reviewing highly liquid investment minimums.

The original November 2, 2022, SEC proposal also included reporting amendments related to funds’ use of swing pricing and to implement a 4 p.m. hard close requirement. Many industry participants voiced their opposition to the proposals, citing costs and the burdens of implementing the measures. While it appears the SEC heeded these concerns and decided not to adopt these proposed amendments in the final rule, they could be reintroduced in the future.

The amendments will become effective November 17, 2025, and funds generally will be required to comply with them for reports filed on or after that date. Fund groups with net assets of less than $1 billion will have until May 18, 2026, to comply with the Form N-PORT amendments.

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<em>This advisory bulletin may be reproduced, in whole or in part, with the prior permission of Thompson Hine LLP and acknowledgment of its source and copyright. This publication is intended to inform clients about legal matters of current interest. It is not intended as legal advice. Readers should not act upon the information contained in it without professional counsel.</em>

<em>This document may be considered attorney advertising in some jurisdictions.</em>

https://admin.thompsonhine.com/wp-content/uploads/2024/08/Investment-Management-Update-SEC-Adopts-Portfolio-Reporting-Enhancements-Declines-Swing-Pricing-and-Hard-Close.pdf

SEC Adopts Portfolio Reporting Enhancements; Declines Swing Pricing and Hard Close

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