The SEC has adopted a temporary final rule that will delay the compliance dates for filing a Form N-PORT. The SEC made this modification in order to evaluate their data security practices for material, nonpublic information and uplift the EDGAR system to securely handle the significant amount of data submitted for N-PORT. The compliance dates for the updated rule have thus been moved from June 1, 2018, to March 1, 2019 for larger fund groups and March 1, 2020 for smaller fund groups. Large fund groups and smaller fund groups will then be required to file a Form N-PORT by April 30, 2019, and April 30, 2020, respectively.
During this transition period, larger fund groups will be required to maintain the Form N-PORT information in their records in lieu of filing the form on EDGAR. Larger fund groups will also be expected to make these records available to the SEC upon request. These two requirements will NOT be applicable for smaller fund groups. However, both fund groups will be required to continue filing the Form N-Q up until the point that they begin filing a Form N-PORT.
As always, Fairview will continue to provide updates as more information is made available.