The U.S. Securities and Exchange Commission (“SEC”) has adopted changes to reporting by mutual funds under the Investment Company Act 1940 which amends the data they must provide under form N-PORT and form N-CEN. It has also published new guidance on some aspects of mutual funds' liquidity risk management programs. The SEC is not taking forward proposals that would have required mutual funds to re-categorize some assets as "illiquid" or to require them to activate swing pricing liquidity risk management tools if certain thresholds are met. The new requirements are:

Form N-PORT and Rule 30b1-9 

• Filings must now be made within 30 days after the end of each month.  The Adopting Release makes explicit that this applies to both open and closed-ended funds; and 

• Monthly reports to be made public 60 days after the end of the month, but the exemptions for some data remain. 

Form N-CEN 

• Funds must name each service provider they use for liquidity risk management purposes along with some further details; and 

• Use separate legal entity identifiers (“LEIs”) and RSSD IDs3 for some different Items and has created a new Item - C22: Liquidity classification services. 

Guidance 

The Adopting Release also contains guidance on certain aspects of liquidity risk management programs, including: 

• Frequency of classification; 

• Meaning of “cash”; and 

• Highly liquid investment minimums. 

A full summary of the new requirements is available here. 

Please contact James Hopegood with any questions.

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  James Hopegood

  Director, Asset Management Regulation