Say What? Keeping Current with U.S. Fund Disclosures

Expectations for U.S. based investment companies’ narrative disclosures continue to evolve from a regulatory and best practices perspective. As a result, boards of trustees, investment advisers and other service providers must remain informed to enable transparency and compliance. This article highlights key areas of focus based on recent regulatory changes, risk alerts and enforcement activity.

Disclosure requirements for registered investment companies (including mutual funds and exchange traded funds, or “funds”) have expanded in recent years, driven by regulatory changes and heightened expectations for transparency. 

Implementing robust disclosure practices is essential for helping to maintain a strong culture of compliance, mitigating legal and reputational risks, and upholding the core principle that investors should have access to full and fair disclosures.

This article explores recent evolutions in narrative disclosure requirements that apply to funds, highlighting key areas of focus for compliance while providing insights on how company policies can be updated to adapt to the regulatory landscape. 

It further explores: 
•    SEC Exams and Disclosures
•    SEC FY 2025 Exam Priorities
•    2024 Risk Alert Observations and Disclosures
•    Recent regulatory changes impacting funds’ disclosure obligations
•    Tailored shareholder reports and disclosure of material fund changes
•    Shareholder reporting amendments
•    Proxy voting and share ownership
•    Names Rule
•    Artificial Intelligence
•    Cybersecurity

Adopting a well-structured and proactive approach to disclosure processes can mitigate compliance risks and demonstrate a commitment to transparency, accuracy and sound governance practices.