Compliance Briefing — November 17, 2025
Open-end funds now must meet the SEC’s amended Form N-CEN disclosures on liquidity risk management partners in the annual filing cycle that closes November 17, 2025.
Executive briefing: The SEC confirmed that the amendments to Form N-CEN adopted alongside the open-end fund liquidity risk management update remain on schedule, with the first amended filings due for the cycle ending November 17, 2025.1 Funds must be ready to identify the service providers supporting their liquidity risk management program and supply refreshed entity identifiers within that Form N-CEN submission.1 Any deferral applies only to the new Form N-PORT cadence, so compliance leads cannot bank on extra runway for the annual Form N-CEN.
Key compliance checkpoints
- Service provider roster. Confirm contracts, roles, and contact information for every vendor that underpins liquidity risk management controls so the Form N-CEN table can be populated without last-minute remediation.1
- Entity identifier governance. Update legal entity identifiers and internal identifiers used across filings to align with the amended data elements, preventing rejection during EDGAR validation.1
- Liquidity program evidence. Align the liquidity risk management team’s documentation—board approvals, annual reviews, and stress-test results—with disclosure narratives so attestations survive examination sampling.
Operational priorities
- Data integration. Build an extract that pulls service provider data from procurement and compliance inventories into the Form N-CEN workflow with audit trails for every edit.
- Control attestations. Refresh internal certifications that trading, risk, and operations heads sign before the Form N-CEN is filed, covering both the service provider roster and liquidity testing cadence.
- Board reporting. Schedule the autumn fund board package to document compliance with the amended Form N-CEN, highlighting any gaps uncovered in vendor due diligence or liquidity modeling.
Enablement moves
- Embed the Form N-CEN data set in the same evidence binder that supports Rule 22e-4 testing so examiners can trace outputs to source approvals.
- Map the Form N-CEN updates into your Form N-PORT and shareholder reporting change logs to keep downstream disclosures synchronized once the N-PORT deferral lapses.
Sources
Zeph Tech unifies fund compliance data, flags Form N-CEN changes, and gives reporting teams one checklist for liquidity risk management filings.