Published on Sep 24th, 2024 |

SEC Disclosure Amendments (N-PORT and N-CEN) - Liam Clarke Insights

Vigilant Insights

Introduction

The SEC made changes to certain disclosure requirements recently involving N-PORT and N-CEN filings. The changes were adopted on August 28th, 2024.

One of the changes requires certain Funds to disclose important information about their Liquidity Service Providers in Form N-CEN.

Effective dates for the changes are November 17th, 2025, for Funds with more than $1 billion AUM, and May 18th, 2026, for Funds with less than $1 billion.

In a recent Ignites article about the possible burden of these requirements, Vigilant Director, Liam Clarke, CPA, MA discusses the impact of this.

Liam Clarke Insights

Liam Clarke Insights

As the SEC continues to adopt new rules and amendments (many of which could cause substantial burden for compliance departments), these new requirements may not be as burdensome by comparison.

The number of adjustments will likely be minimal by comparison to other regulations that are being considered by the SEC, according to Liam.

Most of the information required is already being gathered by the Funds; the amendment reflects a change in the frequency of the filing, from quarterly to monthly, so no major changes to the way Funds operate should be required.

Vigilant's Conclusion

Vigilant’s Conclusion

While these changes should hopefully provide a limited burden, Vigilant is prepared to help Funds through these changes and help them be compliant.

Errors with Regulatory Filings can create further headaches for Firms, and the effective dates arrive faster than expected.

Please reach out to us today with any questions or concerns you may have.

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