FYI: The Division of Investment Management has posted updated FAQs with guidance on investment company reports required under the Investment Company Reporting Modernization Rules adopted in October 2016 and revised in December 2017 and January 2019. The FAQs address questions in the following categories:
• Compliance Dates and General Filing Obligations
• Form N-PORT
• Regulation S-X
• Form N-CEN.
Not surprisingly, the FAQs reveal that funds may be running into unanticipated technical and interpretive issues in preparing their reports stemming from, for example, delays of the compliance dates, differences in methodologies (such as in valuation), funds/classes that have terminated, reporting around fiscal year and quarter ends occurring before and after compliance or reporting dates, total return calculations being required on a monthly basis (when certain loads and fees are not allocated or pro-rated across months), XML filing requirements and a host of other issues. This makes it especially important for funds preparing these reports to consult the FAQs in addition to the rules, instructions and related releases.
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