The U.S. Securities and Exchange Commission has adopted a final rule to enhance reporting requirements for investment funds, including open-end, closed-end, and exchange traded funds, and provide further guidance on liquidity risk management for open-end funds.

Specifically, this final rule requires more frequent and detailed reporting via Forms N-PORT and N-CEN to improve transparency and regulatory oversight. The SEC also clarified that funds must reassess liquidity classifications more frequently during significant market events and specified that "cash" for liquidity purposes refers strictly to U.S. dollars, not foreign currencies.
Additionally, funds are advised to tailor their highly liquid investment minimums based on their specific risk factors and investment strategies. It is worth noting that the SEC did not adopt proposals for mandatory swing pricing or a hard close on NAV calculations and assignments due to massive opposition from the industry.
The final rule will come into force on November 17, 2025; smaller funds may comply with the Form N-PORT amendments from May 18, 2026.
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