Ropes & Gray's Investment Management Update: October – December 2017

The following summarizes recent legal developments of note affecting the mutual fund/investment management industry:

SEC Delays Form N-PORT EDGAR Filing Requirements by Nine Months; N-PORT Data Must be Maintained for the Delay Period

On December 8, 2017, the SEC adopted Temporary Rule 30b1-9(T) under the 1940 Act (the "Rule"). The effect of the Rule is to delay by nine months the EDGAR submission requirements associated with Form N-PORT. During the delay period, funds in "larger fund complexes" (as defined below) must satisfy their Form N-PORT reporting obligations by maintaining in their records the information required to be included in Form N-PORT, instead of submitting the information via EDGAR. The SEC noted that the rationale for the Rule is to provide time for the SEC to complete its review of EDGAR data security issues, as well as to provide SEC staff time to complete and review any modifications to EDGAR that are required to process Form N-PORT filings