Ropes & Gray Releases Investment Management Update

In March, Ropes & Gray released a comprehensive Investment Management Update covering January and February 2026 that summarizes regulatory developments impacting the investment management industry.

Of note for independent fund directors, the Commission issued a release amending the compliance dates for the reporting requirements added to Form N-PORT when the SEC adopted amendments to the Names Rule are extended to November 17, 2027 for registered fund complexes with net assets of $10 billion or more (instead of $1 billion) as of the end of their most recent fiscal year, and to May 18, 2028, for smaller registered fund complexes. The Commission also released a proposal that would amend the definitions of “Small Business” and “Small Organization” for investment companies and investment advisers for purposes of the Regulatory Flexibility Act. The proposed amendments would increase the current asset-based thresholds and propose a mechanism for future periodic inflation adjustments. For investment companies, the current definition of a small entity is net assets of $50 million or less. Under the rule proposal, that threshold would jump to $10 billion. The Ropes update details additional changes that would be implemented if the proposed rule were adopted.

In addition, the Ropes update explains new FAQs added to the original “Fund Names Rule FAQs” from January 2025, highlights Investment Management Division Director Brian Daly’s comments around proxy voting challenges, and notes Chair Atkins’ reported comments around progress on an e-delivery rule proposal allowing funds to deliver electronic documents to shareholders by default instead of mailing physical documents.

Click here to read the Ropes & Gray Investment Management Update.