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On April 16, 2025, the SEC announced a two-year extension of the compliance dates for its <a href="https://www.vedderprice.com/sec-amends-form-n-port-and-n-cen-reporting-requirements-and-issues-guidance-on-open-end-fund-liquidity-risk-management-programs">previously adopted amendments</a> to Form N-PORT reporting requirements. Currently, funds are required to file Form N-PORT on a quarterly basis to report information on a fund’s portfolio holdings as of month-end for each month in the quarter, within 60 days of quarter-end, with information for the third month of the quarter made publicly available. The amendments will require funds to file Form N-PORT on a monthly basis within 30 days of month-end, and information for each month will be publicly available 60 days after month-end. The compliance date is extended from November 17, 2025 to November 17, 2027 for large fund groups (net assets of $1 billion or more as of the end of their most recent fiscal year) and from May 18, 2026 to May 18, 2028 for small fund groups (less than $1 billion in net assets as of the end of their most recent fiscal year). The compliance date for the SEC’s previously adopted amendments to Form N-CEN, adopted with the Form N-PORT amendments in the same August 2024 adopting release, was not extended and remains November 17, 2025. Additionally, the SEC guidance on open-end fund liquidity risk management program requirements, also issued in the same release, is unchanged.

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In the adopting release providing the extension, the SEC cited the <a href="https://www.vedderprice.com/president-trump-issues-regulatory-freeze-memorandum">“regulatory freeze” presidential memorandum</a> issued on January 20, 2025, which directed agencies to consider postponing the effective date for any rules that had been issued but had not yet taken effect in order to review “any questions of fact, law, and policy that the rules may raise.” The SEC also cited a recent industry association request to further amend Form N-PORT, as well as the ongoing case in the U.S. Court of Appeals for the Fifth Circuit challenging the Form N-PORT amendments, which was stayed while the SEC reviews the amendments in accordance with the presidential memorandum. The SEC explained that, in light of these developments, it was extending the compliance dates to provide time for the SEC to complete its review of the amendments in accordance with the presidential memorandum and to take any further appropriate actions, which may include additional amendments to Form N-PORT.

The SEC also stated in the adopting release that it had completed its review of the Form N-CEN amendments and guidance on liquidity risk management program requirements and that those aspects of the August 2024 release were unchanged, also noting that they were not challenged in the Fifth Circuit litigation.

The SEC’s adopting release for the compliance date extension is available <a href="https://www.sec.gov/files/rules/final/2025/ic-35538.pdf" target="_blank" rel="noreferrer noopener">here</a>, and a related press release is available <a href="https://www.sec.gov/newsroom/press-releases/2025-64?utm_medium=email&amp;utm_source=govdelivery" target="_blank" rel="noreferrer noopener">here</a>.

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