U.S. SEC Proposes to Scale Back 2024 Form N-PORT Amendments While Leaving Substantive Names Rule Requirements Intact

On February 18, 2026, the U.S. Securities and Exchange Commission (SEC or Commission) proposed amendments¹ to Form N-PORT reporting requirements for applicable registered investment companies, including registered open-end and closed-end funds, as well as certain exchange-traded funds (ETFs) organized as unit investment trusts. The amendments, which relate to Form N-PORT amendments adopted in 2024 but paused by the SEC in April 2025, would

(i) extend the monthly filing deadline that would have applied under the 2024 amendments from 30 to 45 days after month-end

(ii) reduce the frequency with which portfolio holdings reported to the SEC are made public to quarterly, consistent with the requirements that applied prior to the 2024 amendments

(iii) streamline or eliminate certain other reporting items

(iv) add limited new reporting requirements for ETF share classes

(v) require registered funds to report additional identifying information

Importantly, while the proposal would eliminate certain Form N-PORT reporting requirements relating to the Names Rule, it does not reopen or revise the substantive 80% investment policy requirements adopted under the Names Rule. The core Names Rule compliance obligations and related prospectus requirements remain unchanged.

As background, an April 2025 SEC rulemaking delayed compliance with the 2024 amendments to give the agency time to further evaluate the rules in light of President Donald Trump’s inauguration-day memorandum (sometimes called a “freeze memorandum”), which directed federal agencies to “consider postponing” rules that had been published but not enacted to allow for additional analysis of “fact, law and policy.” The agency also was mindful of litigation by a trade association challenging the 2024 amendments. This sequence of events is important as the current proposed rule may be viewed as unwinding the 2024 rule changes (that never went into full effect) and reverting to the pre-2024 N-PORT regulatory environment.

Comments on the proposal are due 60 days after publication in the Federal Register.  

Extension of Filing Deadline

Under the current rules, issuers are required to file Form N-PORT within 60 days after quarter-end. While the 2024 amendments would have shortened that timeframe to 30 days after month-end, the proposed amendment would extend the filing deadline for Form N-PORT to 45 days after month-end.² The Commission states that while more frequent filings could provide the staff with enhanced information about funds’ portfolio activities, the proposed 45-day timeframe  is “designed to reduce the risk of errors in the reported information and reduce reporting burdens while continuing to recognize that Form N-PORT information is more valuable to the Commission and staff when it reflects more current portfolio holdings and related information.”³ The proposal would make the operational timeline materially more manageable than the 30-day regime contemplated by the 2024 amendments.

Reduction of Public Disclosure Frequency

Under the 2024 amendments, registered funds would have been required to publicly disclose their portfolio holdings every month with a 60-day delay at the end of the relevant month. The proposed amendment would reduce the required frequency of publication to the third month of each fiscal quarter, with the same 60-day delay after quarter-end.⁴ This would return the frequency and timing of public disclosure to the pre-2024 framework. In proposing this amendment, the SEC noted that frequent publication of portfolio holdings carries the “risk of external parties inferring a registered fund’s proprietary trading strategy or trading intentions from Form N-PORT reports and acting on that information in a way that is harmful to the fund.”⁵

Streamlining and Eliminating Reporting Items

The proposed amendments would streamline reporting in the following areas, with the goal of each amendment being “to refine the information funds provide while maintaining the usability and reliability of Form N-PORT data.”⁶

Portfolio-Level Risk Metrics

• Scope of funds required to report: This would reduce the scope of registered funds required to report portfolio-level risk metrics to funds whose debt exposure for the previous three months exceeds 50% of their net asset value, as opposed to the current 25% threshold.⁷

• Interest Rate Risk: Currently, registered funds are required to report two interest rate risk metrics, DV01 and DV100. DV01 reflects the change in value of a fund’s portfolio resulting from a 1 basis point change in interest rates, while DV100 reflects the change in value from a 100 basis point change in interest rates. The proposed amendments would eliminate the DV01 metric and aggregate DV100 reporting across all currencies.⁸

• Credit Spread Risk: This would permit funds to aggregate investment grade and non–investment grade credit spread risk metrics⁹ rather than separately reporting those exposures.

Returns Reporting

• Multiple Class Funds: This would report multiple class funds’ return information for a single representative class rather than for each class.

• Calculating Returns: This would calculate returns without deducting sales loads or redemption fees.

• Derivatives Related Reporting: This would report derivatives gains or losses by asset category only and not by instrument type.

• Period of Returns Information: This would cover the preceding three months rather than one month (as the rule amendments propose to reduce publication frequency to quarterly reporting).

The proposed amendment would eliminate the following reporting obligations:

• Names Rule: Under the prior rules, a fund subject to the 80% Names Rule¹⁰ test would have been required to report quarterly on Form N-PORT certain metrics to demonstrate compliance with the test, including (i) definitions of terms used in registered funds’ names, (ii) the value of the fund’s 80% basket as a percentage of the value of the fund’s assets, and (iii) identification of each portfolio holding in the 80% basket. The purpose of this reporting was to “provide market-wide insight with respect to those registered funds that are subject to the 80% investment policy requirement for the Commission, its staff, and market participants.” The proposed amendments eliminate these Names Rule–related reporting requirements on Form N-PORT as the SEC believes that “there are other sources of information to help investors, the Commission, and its staff understand how a registered fund invests in accordance with the Names Rule, including fund prospectuses and portfolio information.” To provide time to consider these proposed amendments to the Form N-PORT related Names Rule requirements, the SEC extended the compliance dates for Form N-PORT–related Names Rule requirements under the prior rules to November 17, 2027, for fund groups with net assets of $10 billion or more and May 18, 2028, for fund group with less than $10 billion in net assets, each as of the end of their most recent fiscal year. For the avoidance of doubt, the compliance dates for the Names Rule requirements adopted under the prior rules that are not related to Form N-PORT will remain June 11, 2026, for fund groups with net assets of $1 billion or more and December 11, 2026, for fund groups with less than $1 billion in net assets, each as of the end of their most recent fiscal year. 

• Payoff profile for nonderivatives: This would eliminate payoff profile classification (i.e., long, short, or N/A).

• Convertible securities: This would remove information about convertible debt securities, specifically the conversion ratio and delta.

• Multiple Liquidity Classifications: This would eliminate the requirement to state why a holding has multiple liquidity classifications.

Reporting Requirements for ETF Share Classes

Pursuant to the proposed amendment, registered funds with ETF share classes would additionally be subject to certain new reporting requirements, including the disclosure of an ETF class’s net assets, shareholder flows, and ticker information. The new disclosures are intended to enhance SEC understanding of the ETF industry’s structure and growth, as ETF share classes increase in number and net assets. 

Additional Identifying Information

Finally, the proposed amendment would require all registered funds to report additional identifying information on Form N-PORT, including the registrant’s ticker symbol, as well as class name and EDGAR identification number. This aspect of the amendment is intended to be a low-burden addition that will improve the staff’s data standardization and analysis.

Transition Period

The SEC proposes tiered compliance with the proposed amendments, whereby large fund families with $10 billion or more in assets under management would be provided a 12-month transition period, while smaller fund families with less than $10 billion in assets under management would be provided an 18-month transition period. 

Our Take

If adopted as proposed, the amendments can be expected to lower operational risk and cost for funds relative to the framework contemplated by the 2024 amendments, as the filing timeline would be extended, the frequency of public disclosure would be reduced, investment strategy exposure concerns would be reduced, and certain reporting elements would be simplified or eliminated. 

Law clerk Victoria Kageni contributed to this Sidley Update. 

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¹ Form N-PORT Reporting, Investment Company Act Release No. 35962 (proposed Feb. 18, 2026), https://www.sec.gov/files/rules/proposed/2026/ic-35962.pdf.

² Proposed Rule 17 C.F.R. § 30b1-9. 

³ Form N-PORT Reporting, supra note 1, at 5-6. 

⁴ Id. at 25; Form N-PORT and Form N-CEN Reporting; Guidance on Open-End Fund Liquidity Risk Management Programs, Investment Company Act Release No. 35308 (Aug. 28, 2024) [89 FR 73764 (Sept. 11, 2024)] (“2024 Adopting Release”), https://www.sec.gov/files/rules/final/2024/ic-35308.pdf.

⁵ Form N-PORT Reporting, supra note 1, at 10. 

⁶ Id. at 36. 

⁷ Id. at 39. 

⁸ Id. at 40. 

⁹ Id. at 41; See Investment Company Reporting Modernization, Investment Company Act Release No. 32314 (Oct. 13, 2016) [81 FR 81870 (Nov. 18, 2016)] (“Reporting Modernization Adopting Release”), at nn.462-464 and accompanying text.

¹⁰ The Names Rule amendments, among other things, broadened the scope of the requirement for certain funds to adopt a policy to invest at least 80% of the value of their assets in accordance with the investment focus that the fund’s name suggests (an “80% investment policy”) and added reporting requirements on Form N-PORT related to a registered fund’s compliance with that rule.