MFDF - Mutual Fund Directors Forum - Forum Submits Comment Letter in Response to SEC Disclosure Modernization Proposal

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Forum Submits Comment Letter in Response to SEC Disclosure Modernization Proposal

Last week, the Forum submitted a comment letter to the SEC regarding proposed amendments to certain reporting requirements for investment companies and investment advisers in order to “modernize and enhance the reporting and disclosure of information.” The proposed rule would add new forms N-PORT and N-CEN to replace forms N-Q and N-SAR, respectively. Additionally, the proposal would allow funds to satisfy the requirement to deliver shareholder reports by posting them on a public website.

The Forum expressed its support for the efforts of the SEC embodied in the proposal and emphasized the SEC’s role as the primary regulator of funds. However, the Forum’s letter outlined several concerns about the proposal and asked the Commission to consider the increased costs that additional reporting obligations could impose; to limit the data collection to that information which is reasonable necessary for its regulatory purposes; and to extend the compliance period for the rules for all funds. Also, given the sensitive nature of much of the data to be collected, the Forum’s letter encouraged the SEC to take all necessary steps to ensure the security and integrity of the data. Lastly, the Forum applauded the SEC’s proposal to allow funds to deliver shareholder reports by posting them on a public website.