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On February 18, 2026, the SEC proposed amendments to Form N-PORT reporting requirements that would, among other things, change certain amendments that the SEC adopted in 2023 and 2024 for which the compliance dates have not yet been reached. &nbsp;&nbsp;

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SEC Adopts Amendments to Fund Names Rule, Broadening the Scope of Funds that Must Comply. In <a href="https://www.vedder.com/insights-events/sec-adopts-amendments-to-fund-names-rule-broadening-the-scope-of-funds-that-must-comply/">September 2023</a>, the SEC adopted amendments to Rule 35d-1 under the Investment Company Act of 1940 (the Names Rule), which included Names Rule-related Form N-PORT reporting requirements. In <a href="https://www.vedder.com/insights-events/sec-amends-form-n-port-and-n-cen-reporting-requirements-and-issues-guidance-on-open-end-fund-liquidity-risk-management-programs/">August 2024</a>, the SEC adopted additional amendments to reporting requirements on Form N-PORT, requiring funds to file Form N-PORT on a monthly basis within 30 days of month-end and making information for each month publicly available 60 days after month-end. In <a href="https://www.vedder.com/insights-events/president-trump-issues-regulatory-freeze-memorandum/">January 2025</a>, President Donald Trump issued a presidential memorandum ordering all executive departments and agencies to, among other things, consider temporarily postponing the effective dates of certain previously adopted regulations. In <a href="https://www.vedder.com/insights-events/sec-extends-compliance-dates-for-names-rule-amendments/">March 2025</a>, the SEC announced a six-month extension of the compliance dates for its previously adopted amendments to the Names Rule, including related Form N-PORT reporting requirements. In <a href="https://www.vedder.com/insights-events/sec-extends-compliance-dates-for-form-n-port-amendments/">April 2025</a>, the SEC announced a two-year extension of the compliance dates for its August 2024 amendments to Form N-PORT reporting requirements, pushing them out to dates in 2027 or 2028 (depending on the size of the fund group). As a result, compliance with the aforementioned amendments to Form N-PORT reporting requirements is not yet required.

<strong>February 2026 Proposed N-PORT Amendments</strong>

If adopted, the February 2026 proposed amendments to Form N-PORT reporting requirements would:

Require that Form N-PORT filings be made no later than 45 days after month-end, which is an extension of the 30-day deadline adopted in the August 2024 amendments but a reduction from the prior deadline of 60 days after the end of the applicable quarter (note that compliance with the 30-day deadline is not yet required);

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Maintain the quarterly frequency of public reporting of Form N-PORT filings, including portfolio holdings information, by reversing the monthly public reporting cadence that was adopted in the August 2024 Form N-PORT amendments (note that compliance with the monthly public reporting requirement is not yet required);

Streamline reporting requirements by narrowing the scope of certain information collected on portfolio level risk metrics and returns; eliminating certain information related to Names Rule requirements, payoff profiles of non-derivatives instruments, convertible bonds, and, as applicable, the reason a single holding has multiple liquidity classifications; and

Add reporting requirements with respect to funds that have share classes that operate as exchange-traded funds.

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Public comments on the February 2026 proposed Form N-PORT reporting amendments are due on or before April 24, 2026.

<strong>February 2026 Extension of Compliance Dates for Prior Form N-PORT Amendments</strong>

Also on February 18, 2026, the SEC adopted a final rule further extending the compliance dates for the amendments to Form N-PORT reporting requirements that were adopted in September 2023 as part of amendments to the Names Rule. Compliance with the Names Rule-related Form N-PORT reporting requirements has been extended to November 17, 2027 for fund groups with net assets of $10 billion or more as of the end of their most recent fiscal year, and to May 18, 2028 for fund groups with less than $10 billion in net assets as of the end of their most recent fiscal year. The SEC stated that the compliance date extensions are intended to avoid certain costs of compliance with requirements that the SEC has proposed to eliminate.

The SEC’s proposing release for amendments to Form N-PORT reporting requirements is available <a href="https://www.sec.gov/files/rules/proposed/2026/ic-35962.pdf">here</a>, a related press release is available <a href="https://www.sec.gov/newsroom/press-releases/2026-19-sec-proposes-amendments-reduce-burdens-reporting-fund-portfolio-holdings">here</a>, and a related fact sheet is available <a href="https://www.sec.gov/files/ic-35962-fact-sheet.pdf">here</a>.

The SEC’s adopting release for the compliance date extension of Names Rule-related Form N-PORT reporting requirements is available <a href="https://www.sec.gov/files/rules/final/2026/ic-35963.pdf">here</a>.

SEC Proposes Amendments to Form N-PORT Reporting and Extends the Compliance Dates for Prior Form N-PORT Amendments

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