SEC Acts on N-PORT and Names Rule; Staff Issues FAQs: What Funds Need to Know

Form N-PORT Proposal

On February 18, 2026, the Securities and Exchange Commission (SEC) announced proposed amendments (the Proposed Amendments) to certain reporting requirements on Form N-PORT, the form that has been used by registered open-end and closed-end management investment companies (other than money market funds and small business investment companies) and exchange-traded funds (ETFs) organized as unit investment trusts (collectively, reporting funds) to report portfolio holdings and other related information. The SEC noted that the Proposed Amendments are intended to “reduce reporting burdens without significantly affecting the SEC’s use of the data or the public’s ability to assess relevant information about a [reporting] fund.”¹

Notably, the Proposed Amendments would modify the more frequent filing and publication requirements required by the amendments adopted by the SEC in 2024 (the 2024 Amendments).² In April 2025, the SEC delayed the effectiveness of the 2024 Amendments³ and conducted further review of the 2024 Amendments, following a Presidential Memorandum directing agencies to review rules that had not yet taken effect and feedback from market participants, which has now resulted in the Proposed Amendments. The Proposed Amendments, if adopted, would, among other things:

• Provide reporting funds with an additional 15 days to file reports on Form N-PORT of portfolio-related information, extending the monthly filing deadline from within 30 days to 45 days of month end;
• Reduce the frequency of publication of reports on Form N-PORT from monthly (within 60 days of each month end) to quarterly (within 60 days after fiscal quarter end);
• Remove or streamline certain reporting items, including modifications to portfolio level risk metrics and return information and removal of reporting requirements related to Rule 35d-1 under the Investment Company Act of 1940 (the Names Rule);⁴ and
• Add certain identifying information, such as ticker symbols as well as additional information regarding reporting funds with share classes that operate as ETFs (e.g., the ETF class’s net assets and shareholder flows).

The Proposed Amendments will be published in the Federal Register, and the comment period will close 60 days after such publication.

Extension of the Compliance Reporting Date for Names Rule Reporting Items on Form N-PORT

Concurrently, but in a related adopting release,⁵ the SEC extended the compliance dates for the Form N-PORT reporting requirements related to the Names Rule, allowing time for the Proposed Amendments to be considered prior to reporting funds incurring additional costs for reporting requirements that may be eliminated. The compliance dates for the Names Rule-related reporting requirements on Form N-PORT have been extended to November 17, 2027, for reporting fund groups with net assets of $10 billion or greater and May 18, 2028, for reporting fund groups with less than $10 billion in net assets, both determined as of the end of a reporting fund group’s most recent fiscal year end.

SEC Staff Issues Long-Awaited New Names Rule FAQs

Separately, the SEC staff (Staff) issued several long-awaited “Frequently Asked Questions” (FAQs) regarding the Names Rule. These FAQs were added to the already-existing 2025 FAQs⁶ and confirmed:

• 60 days’ notice will not be required for changes to a nonfundamental 80% policy “solely to comply with the amended rule” or for “changes to make the policy more stringent consistent with the fund’s current strategy made in light of the name’s treatment under the amended rule.”
• Unfunded commitments held in cash or cash equivalents covering equity investments in an underlying private fund or special purpose vehicle that owns or will own one or more private assets may count toward a fund’s 80% policy to the extent that the equity investments themselves would count, provided that the fund reasonably expects the commitments to be called in the future and the fund includes explanatory disclosure regarding its intention to take this approach.
• “Growth” or “Value” will not need 80% policies when “used in combination with a modifying term that clearly indicates “growth” or “value” investments are not the predominant component of the fund’s portfolio, and assuming no other aspect of the name otherwise would require the fund to adopt an 80% [policy].” The FAQs also specifically provide an example, “income” in combination with “growth,” which the Staff stated “generally indicates the fund seeks to achieve a portfolio-wide outcome of growth of capital, along with current income.”
• The terms “merger” and “merger arbitrage” suggest an investment technique, like “long/short” or “hedged,” or a portfolio result to be achieved (like “real return”) and will not require an 80% policy.

Notably absent from the new FAQs was an FAQ confirming that funds with the term “Commodity,” “Commodity Strategy,” “Managed Futures Strategy,” or a similar term in its name that seek a portfolio-wide outcome of exposure to such term(s) (such as through derivatives instruments) would not need an 80% policy tied to those terms. Many such funds historically have not invested at least 80% of their assets in investments that may be suggested by such term(s), such as physical commodities or commodity-linked derivatives instruments. These funds instead generally have sought exposure at the portfolio-wide level to the asset class or type suggested by the term(s) in their names through derivatives. These derivatives positions require only a small outlay of cash relative to their notional amounts, and many funds have invested the remainder of their assets in in fixed-income securities that may not be excluded from the definition of “assets” under the Names Rule.