Notice to Forms N-CEN and N-PORT Filers

Date of Notice: February 12, 2018

On October 13, 2016, the SEC adopted, among other things, new Forms N-PORT and N-CEN, to enhance transparency and modernize reporting requirements for registered investment companies (“Adopting Release”).[1]

The SEC recently adopted a temporary final rule which requires funds in larger fund groups  (i.e., fund groups with $1 billion or more in net assets) to maintain in their records the information that is required to be included in Form N-PORT, in lieu of filing reports with the Commission, until April 1, 2019.[2]  The information that funds in larger fund groups maintain in their records will be subject to examination by the Commission.  As a result, larger fund groups will begin filing reports on Form N-PORT with the Commission’s EDGAR system by April 30, 2019 (for the period ending March 31, 2019).  Smaller fund groups (i.e., fund groups with less than $1 billion in net assets) will be required to begin submitting reports on Form N-PORT by April 30, 2020 (for the period ending March 31, 2020).

The Temporary Final Rule does not affect the compliance date for submissions on Form N-CEN.  Accordingly, the compliance date for submissions on Form N-CEN remains June 1, 2018, as set forth in the Adopting Release.

Please note that filers will be permitted to submit test filings of both Forms N-CEN and N-PORT until the compliance date for each form.  The timeframe for test filing submissions is as set forth below and gives effect to the Temporary Final Rule.

Filers may construct XML submissions for reports on Forms N-CEN and N-PORT by following the draft technical specifications posted here: https://www.sec.gov/oit/Article/info-edgar-tech-specs.html.  Form N-CEN filers also have the option of using an online form, which may be accessed by selecting the "File N-CEN" link on the EDGAR Filing Website. 

"Live" filings are not permitted and the system will reject such filings until June 1, 2018, in the case of Form N-CEN and April 1, 2019 in the case of larger fund groups filing reports on Form N-PORT.  Test filings will not be evaluated for legal compliance with the form requirements or be available for public viewing.

Filers should not submit test filings from 3:00 p.m. to 5:30 p.m. Eastern Time each day.  In addition, Form N-PORT filers should be aware that EDGAR will not accept filings with greater than 200,000 holdings during the current testing period.  As with all test filings, personally identifiable information or information that filers may wish to keep confidential should not be submitted.  During the testing periods, testers are strongly encouraged to create and submit fictional data for test filings.  The SEC welcomes feedback from testers on the Form N-PORT and Form N-CEN filing process.  Those who encounter problems during the testing of those forms or who have questions regarding the draft technical specifications may email StructuredData@sec.gov with the subject line "NPORT/NCEN Feedback."