How to Fill Out and File SEC Form N-RN for Open-End Funds

SEC Form N-RN is the current report that registered open-end management investment companies, registered closed-end management investment companies, and business development companies must file within one business day when specific liquidity or derivatives-risk events occur. It is submitted electronically through EDGAR. Money market funds regulated under Rule 2a-7 do not use this form; their event-based reporting goes on Form N-CR instead.¹

Who Has to File

Three types of funds fall within the reporting requirement:

Registered open-end management investment companies, including mutual funds and ETFs organized as management companies, but excluding any fund regulated as a money market fund under 17 CFR § 270.2a-7.
Registered closed-end management investment companies, including interval funds and tender-offer funds registered under the Investment Company Act of 1940.
Business development companies, meaning closed-end companies that have elected to be regulated as BDCs under the Act.

Two rules create the obligation. Rule 30b1-10 (17 CFR § 270.30b1-10) covers the liquidity events in Parts B through D. Rule 18f-4(c)(7) (17 CFR § 270.18f-4(c)(7)) covers the derivatives-related value-at-risk events in Parts E through G.²³ Assets under management do not change the analysis. There is no smaller-fund exemption and no phased compliance date.¹

Events That Trigger a Filing

Form N-RN is event-driven, not periodic. You file only when one of six specific events occurs, and each of the form’s six parts corresponds to one event. Two of the events are breach reports paired with two resolution reports. A single filing can cover more than one event if triggers happen at the same time.

Illiquid Investment Threshold: Parts B and C

Part B is filed when more than 15 percent of a fund’s net assets are or become illiquid investments as defined under Rule 22e-4. The report has to identify each illiquid investment individually, including issuer name, CUSIP, and the percentage of net assets it represents. Part C is the resolution report: once the fund’s illiquid investments drop back to 15 percent or less of net assets, the fund files Part C to close out the breach.¹

Highly Liquid Investment Minimum Shortfall: Part D

Part D applies when a fund’s highly liquid investments fall below its board-approved highly liquid investment minimum for more than seven consecutive calendar days. A shorter dip that self-corrects inside that window does not trigger the report. If the shortfall runs past the seventh day, the fund reports the date it began.¹

VaR Test Breaches: Parts E, F, and G

Parts E and F apply to funds that use derivatives and are subject to the value-at-risk limits under Rule 18f-4. Both parts are triggered when the fund has exceeded its applicable VaR limit and has not come back into compliance within five business days.

Part E (Relative VaR) is used when the VaR of the fund’s portfolio exceeds 200 percent (or 250 percent, depending on the fund’s circumstances under Rule 18f-4) of the VaR of its designated reference portfolio. The filing reports the dates of exceedance, the fund’s portfolio VaR, the reference portfolio’s VaR, and the name or identifier of the designated index.
Part F (Absolute VaR) is used when the fund’s portfolio VaR exceeds 20 percent (or 25 percent) of the fund’s net asset value. The filing reports the exceedance dates, the portfolio VaR, and the fund’s net asset value on those dates.

Part G is the resolution report. Once a fund that filed Part E or Part F returns to compliance with its applicable VaR test, it files Part G with the exceedance dates and the fund’s current portfolio VaR.³

The One-Business-Day Deadline

A report on Form N-RN is due within one business day of the triggering event. If the event happens on a Saturday, Sunday, or SEC holiday, the one-business-day clock starts on and includes the first business day after.¹

For Parts E and F, the triggering event is not the first day the VaR limit is exceeded. It is the fund’s determination that it has failed the VaR test and has not returned to compliance within five business days. The one-business-day filing window runs from that determination, which gives compliance teams a built-in five-business-day remediation period before the reporting obligation attaches.

What Information Goes on the Form

Every filing needs standard identifying information for the entity before the event data:

The official fund name as registered under the Investment Company Act of 1940.
The Investment Company Act file number, which carries an 811- prefix.⁴
The series identifier, if the registrant operates multiple series, so the report is attributed to the correct portfolio.

After the identifiers, you complete only the part or parts that match the triggering event. A fund reporting a new illiquid-investment breach completes Part B; a fund coming back into compliance after a VaR exceedance completes Part G. Parts that do not apply are left blank. Part B is usually the most time-consuming section, because every illiquid holding has to be listed individually with its issuer name, title, CUSIP or other identifier, and percentage of net assets. Assembling that list before you open the EDGAR portal is worth doing given the one-business-day deadline.¹

Filing Through EDGAR

Form N-RN must be filed electronically through the SEC’s EDGAR system. Paper filings are not accepted. The filing portal is at https://www.edgarfiling.sec.gov, and the fund or its filing agent needs valid EDGAR access credentials, including a Central Index Key (CIK) and the associated login codes.¹

Filings must comply with Rule 232.13 of Regulation S-T, which sets the technical format for electronic submissions. EDGAR generates an electronic confirmation once the submission is accepted. If no confirmation arrives, the filing may not have gone through, and you should check EDGAR for error messages before the deadline runs out.

Confidentiality of the Data

Form N-RN is treated differently from most EDGAR filings. The SEC’s stated policy is that it does not intend to make public information reported on Form N-RN that is identifiable to any particular registrant. The Commission may still use Form N-RN information in an enforcement action.¹

Common Mistakes to Avoid

The most frequent scope error is money market funds attempting to use Form N-RN. Funds regulated under Rule 2a-7 report event-based information on Form N-CR, not Form N-RN. Filing one does not satisfy the obligation to file the other.¹

A second common error is confusing Rule 30b1-9 with Rule 30b1-10. Rule 30b1-9 governs the monthly portfolio holdings report on Form N-PORT, a separate filing with its own schedule and content. Rule 30b1-10 is the rule that creates the Form N-RN obligation for liquidity events. Citing the wrong rule in compliance procedures can lead to a missed filing.⁵

The last one is treating a breach report as the end of the obligation. Parts B and C are a pair, and Parts E/F and G are a pair. Filing the breach does not close the matter; the fund still owes the resolution report once it returns to compliance.

1
Securities and Exchange Commission. Form N-RN – Current Report for Registered Management Investment Companies and Business Development Companies
2
eCFR. 17 CFR 270.30b1-10 – Current Report for Open-End and Closed-End Management Investment Companies
3
eCFR. 17 CFR 270.18f-4 – Exemption From the Requirements of Section 18
4
U.S. Securities and Exchange Commission. Investment Company Series and Class Information
5
eCFR. 17 CFR 270.30b1-9 – Monthly Report