The SEC has extended compliance deadlines for the amended Name Rule (Rule 35d-1), giving funds additional time to meet new disclosure, policy, and reporting requirements. Larger fund groups now have until June 11, 2026, and smaller groups until December 11, 2026, to comply. Here’s what legal, compliance, and operations teams should know.
What Is the SEC Name Rule?
The SEC Name Rule (Rule 35d-1 under the Investment Company Act of 1940) was originally designed to prevent misleading fund names. If a fund’s name implies a focus on a specific investment type, industry, or geographic region, it must invest at least 80% of its assets accordingly.
The 2023 amendments significantly broadened the rule:
- Expanded the 80% policy to include names suggesting investment characteristics (e.g., “sustainable,” “growth,” “value”).
- Required quarterly reviews of portfolio alignment with the fund’s name.
- Mandated use of derivatives’ notional value in the 80% calculation.
- Introduced enhanced prospectus disclosures and Form N-PORT reporting.
- Tightened shareholder approval requirements for name-related policy changes.
Updated Compliance Dates
Following implementation challenges raised by industry groups, the SEC extended compliance deadlines as follows:
- Fund groups with $1 billion or more in net assets:
New deadline: June 11, 2026
(originally December 11, 2025) - Fund groups with less than $1 billion in net assets:
New deadline: December 11, 2026
(originally June 11, 2026)
In addition, the SEC adjusted the timing to align compliance with a fund’s fiscal year-end disclosure cycle—avoiding costly “off-cycle” prospectus amendments.
Why the Extension Matters
Fund managers and compliance officers cited several reasons for needing more time:
- The need for cross-functional coordination across compliance, legal, ops, and technology teams.
- Lack of system readiness for enhanced recordkeeping and monitoring.
- Delays in vendor support for implementing the SEC Name Rule amendments.
- Complexity in updating fund names, strategies, and disclosures, especially for funds with multiple subadvisers or derivatives holdings.
This extension provides operational breathing room, especially for funds needing system upgrades or policy restructuring.
Action Items for Compliance Professionals
To ensure smooth implementation by the new deadlines, fund teams should:
- Audit current fund names and confirm whether they imply a covered investment focus or characteristic.
- Evaluate portfolio alignment with the 80% requirement, including derivatives.
- Engage legal counsel and vendors early to update disclosures and tech infrastructure.
- Coordinate board or shareholder approvals if needed for policy changes.
- Align implementation with the fund’s on-cycle fiscal reporting to minimize costs.
Final Thoughts
The SEC’s extension of the Name Rule compliance deadlines is a critical opportunity to prepare for a complex set of rule changes. While the delay offers flexibility, proactive planning remains essential. Compliance, legal, and operations teams should take full advantage of this window to ensure readiness, reduce costs, and uphold transparency for investors.
TillieStar is here to help interpret and operationalize regulatory changes like this one, ensuring your compliance strategy is both effective and efficient.
For any questions on adapting your investment compliance strategy or to learn more about how TillieStar can support your organization, please contact us at sales@tilliestar.com or (617) 865-3550. Explore our services and insights tailored specifically for the asset management industry.