Advisories February 23, 2026

Investment Funds Advisory | SEC Proposes Relaxation of Registered Funds Portfolio Disclosure Requirements

Executive Summary
Minute Read

Our Investment Funds Team explores a Securities and Exchange Commission (SEC) proposal that would allow registered funds to return to quarterly reporting of their public portfolio holdings on Form N-PORT.

  • Earlier this year, the SEC delayed a proposal that would have required monthly reporting of holdings
  • Under the new proposal, funds would now have 60 days after quarter-end to report their public portfolio holdings
  • The comment period will be open for 60 days after the proposal is published in the Federal Register

The Securities and Exchange Commission (SEC) has proposed amendments to Form N‑PORT intended to reduce reporting burdens for registered funds while preserving the SEC’s ability to monitor risks and provide investors with meaningful information. Among other things, the proposal would restore quarterly public reporting of portfolio holdings (rather than publishing monthly data) and streamline certain data elements reported on Form N-PORT.

Currently, registered funds (other than money market funds) must file periodic portfolio reports on Form N‑PORT that include monthly portfolio information. Although quarterly holdings are filed and published, monthly information is reported only to the SEC and not the public.

In 2024, the SEC adopted amendments requiring the public filing of monthly portfolio holdings. Following market feedback and a presidential memorandum, in April 2025 the SEC delayed the effective date of these amendments to allow for a more comprehensive review.

Highlights of the Proposal

On February 18, 2026, the SEC, following completion of its review, proposed new amendments to Form N‑PORT designed to reduce operational burdens, including retaining the framework of quarterly public disclosure without materially affecting the usefulness of reported information. The proposal includes several notable components.

Quarterly public disclosure

The proposals would assure the retention of the long-standing quarterly publication schedule by requiring disclosure of public portfolio holdings only for the third month of each fiscal quarter, subject to a 60-day lag after the quarter-end. This change is designed to mitigate risks associated with monthly public disclosure, including the potential for third parties to use portfolio information to increase costs to funds and shareholders.

Extended filing deadline

Funds would receive an additional 15 days to file their monthly portfolio information on Form N‑PORT, allowing reporting 45 days after month-end. This extension is intended to reduce filing pressures and decrease the likelihood of errors and resubmissions.

Streamlined reporting requirements

In addition, the SEC proposed streamlining Form N-PORT disclosures by:

  • Narrowing certain portfolio-level risk metrics and return information.
  • Eliminating reporting on:
    • Names Rule–related compliance items.
    • Payoff profiles for nonderivative instruments.
    • Convertible bond details.
    • Explanations for multiple liquidity classifications of a single holding.
  • Adding new data fields, such as net assets and shareholder flows for exchange-traded fund share classes, and enhanced identifying information such as ticker symbols.

What’s Next?

The proposing release will be published in the Federal Register. The comment period will remain open for 60 days following publication.


If you have any questions, or would like additional information, please contact one of the attorneys on our Investment Funds team.

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Media Contact
Alex Wolfe
Communications Director