Fast Track to Fine-Tuned: How the SEC's New Form N-PORT Proposed Amendments Refine the Rules for Fund Reporting

On 18 February 2026, the US Securities and Exchange Commission (the SEC) proposed yet another set of amendments to reporting requirements on Form N-PORT (the 2026 Proposal).¹ Currently, Form N-PORT (the Form) is used by certain registered open-end and closed-end funds.² Reports on Form N-PORT provide monthly information about a fund’s portfolio holdings, as well as related information to help assess a fund’s risks, including investment risks (e.g., interest rate risk, credit risk, and volatility risk), liquidity risk, counterparty risk, and leverage.³

The most recent proposal would largely roll back many of the changes made in the August 2024 amendments (the 2024 Amendments) to Form N-PORT. The 2024 Amendments would have increased reporting frequency and accelerated filing deadlines,⁴ requiring affected funds to file monthly Form N-PORT reports within 30 days of each month-end and to report, among other things, information related to newly amended Rule 35d-1 under the Investment Company Act (the Names Rule).⁵ In 2025, the SEC delayed the effective and compliance dates of the 2024 Amendments.⁶ The compliance date for larger fund groups was extended from 17 November 2025 to 17 November 2027, and the compliance date for smaller fund groups was extended from 18 May 2026 to 18 May 2028.

The 2026 Proposal generally seeks to reduce the reporting burdens associated with the 2024 Amendments, address concerns around possible front running of funds’ trading strategies resulting from monthly reporting of holdings, and reduce the new reporting related to the Names Rule.⁷ A detailed comparative chart and related description of the 2024 Amendments and the changes in the 2026 Proposal is included below. Many of the proposed changes respond to issues that were raised by commenters at the time of the 2024 Amendments, and provoked dissent from some commissioners when they were adopted.⁸ While the 2026 Proposal is largely a deregulatory and streamlining effort, it does include notable new requirements related to exchange-traded fund (ETF) share class exemptive relief orders that the SEC has recently granted, as outlined in more detail below.

In a related action, the SEC also extended the compliance dates for the Names Rule-related reporting requirements on Form N-PORT to provide time to consider the proposed amendments to Form N-PORT. Consistent with its extension of the compliance dates under the 2024 Amendments, the SEC extended the compliance dates for the Form N-PORT Names Rule-related requirements to 17 November 2027, for fund groups with net assets of US$10 billion or more; and to 18 May 2028, for fund groups with less than US$10 billion in net assets.⁹ We expect that any final action on the 2026 Proposal would further amend compliance dates to allow firms to adjust their reporting processes accordingly.

The following chart compares the 2024 Amendments with the 2026 Proposal. Following the chart is a more detailed description of the 2026 Proposal.

Details of the Proposal

The proposed revisions to the 2024 Amendments would provide additional filing time, reduce the publication frequency, increase the portfolio level risk metrics threshold, and simplify the interest rate risk metrics. More specifically, the 2026 Proposal would:

Provide Additional Filing Time

The 2024 Amendments would have required funds to file monthly reports within 30 days after month end. The SEC is now proposing to revert the 2024 Amendments to the prior filing deadline of 45 days after month end.¹⁰ The SEC determined that the 30-day deadline was more burdensome than initially anticipated. We expect that reporting funds will benefit from this additional time to confirm reported information, as the shorter window may have put significant pressure on fund back-offices and service providers.

Reduction of Publication Frequency

The 2024 Amendments would have required funds to publish Form N-PORT reports publicly within 60 days after each month end. The SEC proposes to reduce the frequency of public reports on Form N-PORT from monthly (within 60 days after month end) to quarterly (within 60 days after fiscal quarter end).¹¹ This proposal restores the publication frequency that was in place prior to the 2024 Amendments.¹² The change in the 2024 Amendments to monthly public disclosure provoked vigorous opposition from commenters, as there was concern that such frequent exposure of sensitive portfolio information could lead to front running, predatory trading and other investor harm. Even after the adoption of the 2024 Amendments, commenters continued to advocate for a return to quarterly public disclosure,¹³ and the 2026 Proposal reflects these concerns.

Increased Portfolio Level Risk Metrics Threshold

Currently, registered funds subject to reporting on Form N-PORT are required to provide portfolio level risk metrics if the average value of the fund’s debt securities positions for the previous three months, in the aggregate, exceed 25% of the fund’s net asset value. The SEC proposes to increase this threshold to 50% of the fund’s net asset value.¹⁴ Under the proposed amendment, registered funds with less than 50% of their net assets in debt securities, on a three-month average basis, would no longer be required to provide information on portfolio level risk metrics. It has been noted that data captured by the 25% threshold is less relevant as funds investing more than 50% of their net assets in debt securities are more likely to be exposed to risks associated with changes in interest rates or credit spreads.¹⁵ Accordingly, we expect the increased threshold to alleviate operational burdens on reporting while focusing on the utility of data reporting.

Simplification of Interest Rate Risk Metrics

Currently, registered funds are required to report on two interest rate metrics: DV01, which measures the change in value of a fund’s portfolio resulting from a one basis point change in interest rates, and DV100, which measures the change resulting from a 100-basis point change.¹⁶ Under the new amendments, the SEC proposes to modify the interest rate risk metrics as follows: 

Elimination of the DV01 Metric

The SEC proposes to eliminate the reporting of the DV01 metric. The SEC believes that the DV100 metric is more useful for monitoring funds’ exposure to interest rate risk over time.¹⁷

Simplification of the DV100 Metric

The SEC proposes to simplify the DV100 metric by requiring that the metric be aggregated across all currencies (rather than being reported separately for each currency) for which the fund had a value of 1% or more of the fund’s net asset value.¹⁸

Streamlining Information

The SEC proposes to streamline the credit spread risk reporting by no longer requiring funds to report credit spread risk metrics separately for investment grade and noninvestment grade exposures. Credit spread risk metrics are technical data in which many funds faced practical challenges in accurately segmenting and reporting this data. By simplifying the reporting process, we expect a reduction in compliance costs and operational burdens as funds work with service providers to provide this information.¹⁹

Reporting of Returns

The SEC proposes to reform the reporting of returns in four ways:

Multiple Class Reporting

The SEC proposes to simplify reporting of returns by multiple class funds and to provide more specified instructions for funds to calculate returns.²⁰ Currently, registered funds are required to report monthly total returns for each class (if a fund has multiple classes).²¹ Under the SEC’s proposal, returns will be reported for a single representative class and will be calculated in the same way as in the applicable registration form.²² We expect reduced burden for most multiple-class funds on returns while adding targeted, useful granularity for the growing ETF share-class structure. 

Deduction of Sales Loads and Redemption Fees

Additionally, the SEC proposes that a fund’s sales loads and redemption fees are not to be deducted from performance reporting.²³ Currently, total returns are reported in accordance with methodologies outlined in applicable registration forms.²⁴ Furthermore, the current Form N-PORT is out of cadence with the reporting timing required by applicable fund registration forms.²⁵ This is because Form N-PORT provides monthly information while registrants disclose performance metrics on Forms N-1A and N-3 for noncumulative periods of one, five, and 10 years.²⁶ Deducting sales loads and redemption fees for each month over an indefinite number of reports could potentially give investors the impression that these are ongoing fees and would therefore overstate their effect on performance.²⁷ This change could result in more comparable monthly return data on Form N-PORT, with only limited impact to the public’s use of the data, as investors can still see the effect of loads and fees in the return tables in annual reports.

Elimination of Certain Required Reporting By Type of Derivative Instrument

Currently, registered funds subject to reporting on Form N-PORT are required to report the net realized gain (or loss) and net change in unrealized appreciation (or depreciation) attributable to derivatives by asset category.²⁸ Within such asset categories, funds are required to report the same information for different types of derivative instruments, which is intended to help SEC staff, investors, and other potential users to better understand how a registered fund uses derivatives to accomplish its investment strategy and the impact that derivatives have on a fund’s returns.²⁹ The 2026 Proposal would eliminate the requirement to report information by type of derivative instrument, in favor of information by asset category.³⁰ This amendment aligns with the broader 2026 Proposal’s goal of reducing costs and refining data collection without materially impairing risk monitoring or investor transparency.

Return Reporting Made for Each of the Three Months in a Fiscal Quarter

The SEC also proposes that, because Form N-PORT will be submitted quarterly rather than monthly, registered funds will be required to report return information for each of the preceding three months in each report to avoid unintended consequences regarding investor’s access to monthly return information.³¹ As a consequence, the costs savings for the changes may not be as significant as could be expected because funds will be required to continue collecting and submitting granular data about each month in the quarter.

Names Rule Reporting Requirements

In addition to these changes, the SEC has proposed to remove requirements to report information related to the registered fund’s compliance with the Names Rule.³² The Names Rule requires a fund whose name suggests a focus on a particular type of investment, industry, or geographic area to adopt a policy to invest at least 80% of its assets in accordance with its name.³³ The purpose of the Names Rule is to prevent fund names from misleading investors about the fund’s investment risks, particularly where a name could indicate that a fund’s investment decisions incorporates one or more ESG factors.

Removal of Requirements Related to the Names Rule

Under the existing Form N-PORT requirements, funds that are required to adopt the 80% investment policy pursuant to the Names Rule are required to report the following items: (1) definition of terms used in the fund’s name; (2) the value of the fund’s 80% basket, as a percentage of the value of the fund’s assets; and (3) whether each investment in the fund’s portfolio is in the fund’s 80% basket.³⁴ The SEC proposes to remove all three Names-Rule related reporting requirements from Form N-PORT. This proposal will likely be welcomed by the industry, as eliminating these requirements would reduce overall costs associated with filing Form N-PORT, particularly the costs of adding new data tags for Names Rule-related information.

Elimination of Requirements Related to the Payoff Profiles of Nonderivatives

Currently, Form N-PORT requires registered funds to report whether each position is long or short.³⁵ Funds are currently required to report on the value of the holding (positive/negative), and this information can serve as a proxy for whether holdings are long or short. This will eliminate redundancy in reporting and reduce overall compliance burdens.

Elimination of Certain Information About Convertible Debt Securities

On Form N-PORT, registered funds are required to report on the conversion ratio and the delta of certain convertible debt instruments, if applicable. The 2026 Proposal eliminates these reporting requirements as a means of further reducing reporting burdens and streamlining compliance for funds.

Elimination of Explanation to Why a Single Investment Has Multiple Liquidity Classifications

An open-end fund currently is permitted to attribute multiple classifications to a single holding only in the following circumstances: (1) if portions of the position have differing liquidity features that justify the different classification; (2) if a fund has multiple sub-advisers with differing liquidity reviews; or (3) if the fund chooses to classify the position through evaluation of how long it would take to liquidate the entire position.³⁶ If the fund reports multiple liquidity classifications for a single holding, the fund must indicate which of the three permitted reasons led to the different classifications. The 2026 Proposal would eliminate the requirement that open-end funds indicate a specific reason for the multiple classifications, which is likely to simplify liquidity reporting for some funds.

In addition to revising the 2024 Amendments, the 2026 Proposal introduces several new reporting requirements in response to regulatory changes and developments in the asset management industry. Specifically, the new reporting requirements include the following:

ETF Share Class Reporting

The SEC is proposing to add a new requirement for mutual funds with ETF share classes in light of the recently granted exemptive relief for mutual funds to have ETF share classes. The 2026 Proposal requires net assets and flow to be reported separately for an ETF share class as well as for the class’s ticker.³⁷ The SEC asserts that this reporting information is important because not only is an ETF share class structured differently and thus may behave differently than the other share classes in a multiple-class fund, but also that separate information would facilitate SEC staff analysis of industry trends and risks.³⁸

We expect that as firms begin to implement ETF share classes this report will be relevant to understanding the size and scale of investor interest in the new classes, and may provide other valuable insights into their development. While we generally expect that this information should be readily available for funds, adding any additional reporting requirements was a bit of a surprise, given the general focus on deregulatory actions by the current commission.

Additional Identifying Information

The SEC proposes to require registered funds to report the ticker symbol for each registrant and, as applicable, for each class of a registrant or series, along with class names and identification numbers.³⁹ The SEC is encouraging the use of tickers in the Form as the staff has found that ticker symbols enhance the efficiency of data analysis.⁴⁰

Overall, we expect that the amendments will come as welcome relief to many funds. While registrants have successfully established processes to file Form N-PORT in the more than a decade since it was originally adopted, the Form has been in a constant state of flux. The SEC has revised it frequently over the years and has proposed other amendments to the Form that were never adopted. Taking a step back and reviewing what has worked and what has not worked and proposing these streamlined reporting requirements is favorable for the industry in general. Nonetheless, even as part of such a streamlining effort, the SEC has found new areas of information for funds to report, as the market evolves towards ETF share classes.

The 2026 Proposal will be published in the Federal Register shortly, and the comment period will remain open for 60 days after the Federal Register publication date. As funds review and evaluate the proposal, the firm's lawyers are available to help identify areas where the SEC may wish to revise the final amendments and provide feedback accordingly.

We acknowledge the contributions to this publication from our law clerk Stewart J. H. Atkins.