Investment Services Regulatory Update - March 2019

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New Rules, Proposed Rules, Guidance and Alerts -

NEW RULES -

SEC Adopts Interim Final Rule Amending Timing Requirements for Filing Reports on Form N-PORT -

On February 27, 2019, the SEC adopted an interim final rule amending Rule 30b1-9 under the Investment Company Act of 1940 to:

• require reports on Form N-PORT for each month in a fiscal quarter to be filed with the SEC no later than 60 days after the end of that fiscal quarter, rather than 30 days after the end of each month; and

• require that funds, not later than 30 days after the end of each month, maintain the information required on Form N-PORT, and make that information available to the SEC promptly upon request.

These amendments have the effect of delaying the filing deadline for non-public fund data reported on Form N-PORT. The amendments do not change the substance of the information funds will need to provide to the SEC on Form N-PORT, nor do they affect the amount or timing of that information that will be made public. As with the original rule, the reports for the first two months of a quarter will not be publicly released, and the report for the final month of a quarter will be made public upon filing (with the exception of certain items identified on Form N-PORT).

Please see full publication below for more information.

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DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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