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SEC Modifies Timing for Filing Form N-PORT Data

The SEC announced that it has modified the submission deadlines for funds to file non-public monthly reports on Form N-PORT.  Rather than filing non-public monthly reports within 30 days after each month-end, funds will be required to maintain the relevant information in their records and file all three monthly reports with the SEC no later than 60 days after the end of each fiscal quarter. The non-public monthly reports on Form N-PORT for the first and second months of the fiscal quarter will remain non-public and the monthly report for the third month will become publicly available upon filing (with the exception of certain specific data items).  The amount and timing of the information on Form N-PORT that will be made available to the public will not change.  In its release, the SEC said “[A]llowing funds to report this monthly data at quarter end – while not changing the amount or substance of the data – will allow the Commission to fulfill its mission while reducing its cyber risk profile.” Filing Form N-PORT through the EDGAR system will begin in April 2019 for larger fund groups and in April 2020 for smaller fund groups. A client alert from law firm Drinker Biddle discusses the changes and recommendations for directors and fund service providers.

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