SEC Proposes N-PORT Relief | Fred Teufel Insights
Vigilant Insights
Introduction
On February 19, 2026, the SEC announced Proposed Amendments designed to reduce certain operational burdens associated with Form N-PORT reporting while maintaining regulatory transparency. According to the SEC’s press release, the Proposal would preserve monthly reporting to regulators but scale back the frequency of public portfolio disclosures.
The Proposal responds to industry concerns following the SEC’s 2024 Amendments, which would have required Funds to publicly disclose portfolio holdings on a rolling monthly basis. Market participants raised operational, compliance, and front-running concerns, particularly given advances in data analytics and AI that make it easier to analyze portfolio holdings data.
Under the newly Proposed Amendments:
- Funds would continue to submit monthly portfolio holdings to the SEC.
- The deadline to file Form N-PORT would move from 30 days to 45 days after month-end.
- Public disclosure would revert to quarterly, rather than monthly.
- Certain tagging requirements tied to the Names Rule would be eliminated.
The SEC noted that more frequent public disclosure could increase the risk of reverse engineering strategies or front-running trades. The Proposal aims to strike a balance between regulatory oversight and protecting shareholder interests.
One of Vigilant’s Directors, Fred Teufel, CPA, MBA, CGMA, was quoted in Ignites where he provided his thoughts and insights pertaining to the Proposed Amendments and that can be found below.
Fred Teufel Insights
Fred highlighted the significant operational lift Firms were already facing under the 2024 Amendments. Many Fund complexes were in the process of upgrading systems, revising policies and procedures, and accelerating internal review timelines in order to meet the 30-day filing deadline and rolling monthly public disclosure requirements.
According to Fred, some Firms were not fully equipped to produce portfolio reports on such an accelerated timeline. The transition required extensive coordination across compliance, operations, and technology teams, and for many Firms, the burden proved heavier than originally anticipated.
He views the proposed 45-day filing deadline as a more practical and reasonable approach. The additional time would allow compliance teams to properly compile, validate, and review data before submission, reducing the likelihood of errors or re-filings.
While the Proposal does not eliminate the compliance effort entirely, it meaningfully eases the pressure compared to the prior framework.
Vigilant’s Conclusion
The SEC’s Proposal represents a recalibration, not a rollback, of its 2024 N-PORT Amendments. Monthly data would continue flowing to regulators, preserving oversight, while quarterly public disclosure helps mitigate concerns around front-running risk and operational strain.
For Fund Boards and Advisers, the Proposal provides greater flexibility in aligning disclosure practices with investment strategy and shareholder interests. At the same time, compliance obligations remain significant, and Firms should continue evaluating internal processes, reporting controls, and data validation procedures.
Vigilant believes Firms should use this period proactively reviewing current readiness, reassessing reporting timelines, and preparing for final Rule adoption. Even with moderated requirements, strong internal controls and well-documented procedures will remain critical in demonstrating compliance and supporting accurate Regulatory Reporting.