SEC Proposes Revisions to RIC Filing and Publication Requirements

The proposed rulemaking would extend the deadline for funds to file monthly reports to 45 days after the end of the month. Further, the proposal would revert to a quarterly publication schedule, where only the report for the third month of a registered fund’s fiscal quarter is made public 60 days after quarter-end. The SEC said this approach reduces the risk of "free riding" on investment manager research while maintaining appropriate transparency.

The SEC highlighted the following reforms in the proposal: (i) eliminating reporting requirements related to the "Names Rule"—specifically definitions of name terms, the aggregate value of the "80% basket," and individual holding classifications—as well as removing non-derivative payoff profiles and certain liquidity classification narratives; (ii) raising the net asset value threshold for reporting portfolio-level risk metrics from 25 percent to 50 percent and streamlining interest rate and credit spread risk reporting; (iii) requiring funds with ETF share classes to report net assets and shareholder flows separately for the ETF class; and (iv) mandating the reporting of ticker symbols and limiting return "reporting for multiple class funds" to a "single representative class."

The SEC stated that the revisions were necessary to balance the need for timely data against the "operational burdens" and potential risks to funds. The agency highlighted industry feedback indicating that the previously adopted 30-day filing deadline could increase the "risk of errors" and necessitate accelerated internal processes. The SEC acknowledged concerns that monthly public disclosure could allow external parties to "reverse engineer" proprietary strategies or "front run" trades, potentially "harm[ing] fund performance" and shareholders. Comments on the proposal must be submitted no later than 60 days after its publication in the Federal Register.

Separately, the SEC issued a final rule extending the compliance date for Form N-PORT amendments related to the "Names Rule." The compliance dates were extended to November 17, 2027, for fund groups with net assets of $10 billion or more, and to May 18, 2028, for smaller fund groups.