Your Guide to SEC Updates to N-PORT & N-CEN Forms

Since the U.S. Securities and Exchange Commission adopted its rule to modernize disclosures by registered investment companies, fund providers have been adjusting to changes.

The rule, revised in January 2019, introduced two new forms: N-PORT and N-CEN. It required information on both forms be filed to the SEC in XML format so that SEC staff can efficiently analyze the data for trend spotting and risk monitoring.

Here's a high-level look at highlights of the requirements, as well as quick tips for smoother compliance.

What is Form N-PORT?

This form, filed by registered management investment companies and exchange-traded funds (ETFs) organized as Unit Investment Trusts, is used to report on a fund’s portfolio. Money market funds and small business investment companies (SBICs) are excluded.

The rule requires funds to report:

• General information, including a Legal Entity Identifier number
• Assets and liabilities
• A number of portfolio-level quantitative risk metrics for funds with 25% or more invested in debt instruments
• Securities lending, including information on counterparties involved
• Monthly total returns for each of the preceding three months
• Flow information (net asset value of shares sold, shares sold in connection with re-investments of dividends and distributions, and shares redeemed or repurchased) for each of the preceding three months
• Information on each investment in the portfolio
• Miscellaneous securities
• Explanatory notes, if any
• Exhibits

Because this overlaps with information on the previous Form N-Q, Form N-Q is no longer required.

What is Form N-CEN?

Form N-CEN provides basic fund information, including details like the chief compliance officer's name, and replaces Form N-SAR. Registered investment companies including money market funds are required to file Form-NCEN. On the plus side, it is filed annually (unlike N-SAR, which was filed semiannually).

Here is a breakdown of the different areas of Form N-CEN by fund:

• All funds complete parts A and B and file required attachments
• All management companies, other than SBICs, will complete Part C
• Closed-end funds and SBICs will complete Part D
• ETFs, including those that are UITs, and exchange-traded managed funds will complete Part E
• UITs will complete Part F

What are the N-CEN and N-PORT filing deadlines?

N-PORT

Under the revised rule from January 2019, a fund must file N-PORT for each of the three months in a fiscal quarter within 60 days of the end of that quarter. (Fund companies need to have the data on hand within 30 days after the end of each month.) Information reported for the third month of each fund’s fiscal quarter is intended to be made publicly available.

N-CEN

As with the old N-SAR schedule, management companies will file N-CEN on a fiscal year basis, while UITs will file on a calendar year basis. N-CEN must be filed within 75 days.

When must funds start filing N-PORT?

Larger fund groups started submitting Form N-PORT to EDGAR beginning May 2019. The revised rule gave small fund groups with less than $1 billion in net assets until June 1, 2020, to file their first reports on Form N-PORT on EDGAR for the period ending March 31, 2020. (They must comply with the data retention requirement starting April 1, 2020.)

What about liquidity information on N-CEN and N-PORT?

From here on out, funds should be reporting liquidity information on N-CEN.

The compliance date for smaller fund groups to report liquidity information on N-PORT was pushed back to Dec. 1, 2019.

SEC resources

The SEC is the definitive source for details on N-PORT and N-CEN. Resources online include:

• Helpful information and links in its FAQs, published June 21, 2019
• The original rule published in 2016
• Amendments adopted in 2017
• The revised rule, published January 2019
• The EDGAR Form N-PORT XML Technical Specification (Version 1.7)

Quick tips for smoother compliance

No doubt, the complexity of gathering the required information for each fund, the volume of information to be reported across all your funds, and the reporting deadlines can be daunting.

1. Use technology to simplify data aggregation
2. Eliminate duplicative tasks
3. Automate what you can
4. Work with a software provider with an out-of-the box solution and services for meeting the requirements

Based on the evolution of N-PORT requirements alone, we know that regulations can change. As you prepare for a smooth N-PORT and N-CEN filing process, look for solutions that can help you nimbly adapt with each update of disclosures and filing requirements.

Workiva recently announced a partnership with FilePoint which enables users to export their data for Forms N-PORT and N-CEN from the Workiva connected reporting platform into the FilePoint solution. Investment companies can then edit, review, approve, and work with the FilePoint service team to file those forms directly with the SEC.

For an up-close look at how the partnership between Workiva and FilePoint can support your filing process, request a demo.