Funds Face New Reporting Challenges

Terry Flanagan

The U.S. Securities and Exchange Commission’s initiative to modernize reporting will require significant work by investment companies and advisors, who will need to sort through multiple data sources in order to satisfy the requirements.

Under the SEC’s proposals released last week, funds would report portfolio and census information in a structured data format, which would improve the ability of the Commission and the public to aggregate and analyze information across all funds and to link the reported information with information from other sources.

The SEC currently receives this type of reporting for both money market funds, through Form N-MFP, and certain private funds, through Form PF.

“Aggregating information from multiple structured and unstructured source files to prepare a single filing is no easy endeavor, as the people who have been struggling with Form PF and Form N-MFP know all too well,” said Paul Soltis, North America market manager at Confluence, a provider of data management and reporting products for the asset management industry.

A new monthly portfolio reporting form, N-PORT, will require registered funds other than money market funds to provide portfolio-wide and position-level holdings data to the Commission on a monthly basis. The form would require monthly reporting of the fund’s investments, including data related to the pricing of portfolio securities, and information regarding repurchase agreements, securities lending activities, and counterparty exposures.

“It’s far bigger than the most recent systemic risk filings (Forms PF and N-MFP) out of the most recent systemic risk filings that are out there,” Soltis said. “It’s really expanding the need to manage and report on systemic risk data, and that’s a pretty big challenge.”

The proposed amendments to the investment adviser registration and reporting form (Form ADV) would require investment advisers to provide additional information for the Commission and investors to better understand the risk profile of individual advisers and the industry.

“Whereas Form N-MFP currently impacts about 600 money market funds, and Form PF impacts about 5,000 private fund advisors, Form N-PORT is going to impact about 13,000 mutual funds, while the changes to ADV for systemic risks are going to impact about 9,000 separately managed account advisors,” Soltis said.

Confluence has been aware that the SEC would be announcing Form N-PORT since early 2014. “The SEC has made no secret of how much they love the information they get from Form N-MFP and Form PF,” said Soltis. “They’ve also made no secret of how disappointed they are that there’s this huge gap in their ability to collect data on systemic risk from the asset management industry, that gap being they don’t collect information on mutual funds and they don’t collect that information on SMAs.”

Soltis said he was also anticipating the announcement of Form N-CEN, a new annual reporting form for fund census information that replaces Form N-SAR. However, he was surprised by the proposal to drop Form N-Q, on which funds currently report certain portfolio holdings for the first and third fiscal quarters, as well as the proposal that funds deliver annual reports on their website in lieu of paper.

Confluence, whose products encompass regulatory reporting, performance reporting, financial reporting, and expense management, will add features to support the new reporting requirements. “We’ll build out a solution to N-PORT to help support that data-management reporting challenge,” said Soltis.

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