SEC Extends Form N-PORT Reporting for Names Rule and Publishes More Names Rule FAQs

March 4, 2026

What happened?

On February 18, the SEC issued an extension of the compliance dates for Form N-PORT reporting related to the “Names Rule,” proposed new amendments to Form N-PORT reporting, and published new questions and answers on the Names Rule FAQ.

Form N-PORT Reporting Under the Names Rule

The SEC extended the Form N-PORT reporting requirements connected to the Names Rule to November 11, 2027, for fund groups with $10 billion or more in net assets and May 18, 2028, for fund groups with less than $10 billion in net assets.

Separately, the SEC proposed amendments to Form N-PORT. If adopted, these amendments could (1) move the monthly deadline for reporting portfolio-related information from within 30 days of month-end to within 45 days of month-end; (2) lower the frequency of publication from monthly to every 60 days; (3) reduce the number and detail of reporting items; and (4) add additional identifying information such as ticker, ad share classes that operate as ETFs. The comment period is open for 60 days from publication. The submission form is located here for making a public comment.

Added Names Rule FAQs

Four new questions were answered by SEC staff and added to the 2025 Names Rule FAQ. Generally, under the Names Rule, when a fund’s name suggests a focus in a particular type of investment, particular industry, particular geographic area, or particular investment characteristic, the fund must adopt a policy to invest at least 80% of fund assets in that focus area. Funds may elect to make the 80% investment policy a fundamental policy, where the fund would need shareholder approval to make a change, or a non-fundamental policy, where the fund could change the policy by providing shareholders notice at least 60 days prior to a change.

The Names Rule created a lot of questions around what names are suggestive of a particular focus and what approval, notice, or action is needed for investment policy changes in different circumstances. The SEC staff answered the following questions in the latest updates:

• 60-day notice – Although material changes to a non-fundamental 80% investment policy do need notice, non-material changes made to comply with the amended rule do not. Likewise, changes to make a policy more stringent within the fund’s current strategy in light of the name’s treatment under the amended rule would not need a 60-day notice.
• Unfunded Commitments – A common question was how to count unfunded commitments for the 80% investment policy value of the fund’s assets. The SEC staff clarified that unfunded commitments held in cash and cash equivalents covering equity investments in an underlying private fund or special purpose vehicle that owns or will own one or more private assets may be counted in the fund’s 80% basket so long as (1) the fund reasonably expects the commitments to be called in the future, and (2) there is an explanatory disclosure in the fund’s registration statement describing this intention to count unfunded commitments in this manner.
• Names that pair “growth” and “value” with modifying terms – Where the term “growth” or “value” is used in combination with a modifying term that clearly indicates “growth” or “value” investments are not the predominant component of the fund’s portfolio, and assuming no other aspect of the name otherwise would require the fund to adopt an 80% investment policy, then the staff would not require an 80% investment policy with respect to the term “growth” or “value.”
• Use of the term “income” paired with “growth” – Here the SEC staff indicated that “income,” when paired with “growth,” conveys something different than what “growth” conveys on its own. The SEC staff understand that the combination of the terms “income” and “growth” generally indicates the fund seeks to achieve a portfolio-wide outcome of growth of capital, along with current income. In the staff’s view, an 80% investment policy with respect to the term “growth” would not be required in these circumstances.
• Names with the term “merger” or “merger arbitrage” – Another common question was if the term “merger” or “merger arbitrage” would need an 80% investment policy. The SEC staff said no, “[i]n the staff’s view, this suggests an investment technique (like “long/short” or “hedged”) or a portfolio-wide result to be achieved (like “real return”) that does not require the adoption of an 80% investment policy.”

What does this mean for me?

All of the requirements of the Names Rule outside of Form N-PORT reporting still have their original compliance deadlines of June 11, 2026, for large fund groups and December 11, 2026, for small fund groups (see our prior coverage on the rule, the original FAQs). This means the 80% investment policy requirement and the requirements around notices and shareholder approval are still live and will come due soon.

The SEC under Atkins can be hard to predict. Last year, the 2025 compliance deadlines of the Names Rule were extended. Now, by only extending the 2026 deadlines for the Form N-PORT provisions of the Names Rule, it appears that the SEC intends to keep the current deadlines for the rest of the requirements. Publishing additional FAQs now might also indicate that the June 11, 2026, deadline will stay put for all the requirements other than Form N-PORT Reporting.

To be prepared, use the new FAQs to inform your approach to Names Rule compliance. The deadline for large fund groups is approaching, and the SEC may not grant any additional time to comply. We will continue to monitor regulatory updates and new developments that impact investment advisers and compliance programs. If you have questions, contact us. Fairview is here to help.