The U.S. Securities and Exchange Commission (SEC or Commission) unanimously approved a proposal (Proposal) to modernize the reporting of information provided by registered investment companies (funds). Guided by the recent implementation of enhanced data reporting requirements for money market funds that make filings on Form N-MFP and for private funds that make filings on Form PF, the Proposal is designed to improve the quality and type of information that all funds provide to the SEC and investors. Among other things, certain new reporting requirements would be provided in a “structured data format,” which would allow the SEC to efficiently analyze the data to respond to market, fund-specific or adviser-specific events. As SEC Chair Mary Jo White stated at the open meeting at which the Proposals were approved, the Proposal would allow the SEC to have “more and better information to monitor risks in the asset management industry.”

The Proposal has four key components:

- Adoption of Form N-PORT, for reporting portfolio-wide and position-level holdings information, and the rescission of Form N-Q;

- Revisions to Regulation S-X that would standardize reporting of derivatives holdings in financial statements;

- Adoption of Rule 30e-3, to allow funds to provide website disclosure of shareholder reports in lieu of mailing; and

- Adoption of Form N-CEN, for reporting census-type information, and the rescission of Form N-SAR.

This Dechert OnPoint summarizes these key components of the Proposal and highlights issues that may be raised by this new reporting regime.