SEC Proposes Updates to Filing Fee Disclosure and Payment Methods

November 8, 2019

On October 24, 2019, the SEC issued a release proposing amendments to various rules and forms under the 1933 Act, 1934 Act and 1940 Act (Release) applicable to investment companies registered under the 1940 Act (funds). The amendments would, among other things, require filing fee disclosures under Forms N-2, N-5 and N-14 to be structured in Inline eXtensible Business Reporting Language (XBRL) format and would require the cover page of affected forms to include all information necessary to calculate the filing fee. The amendments would also change the method for paying filing fees by adding an Automated Clearing House option and eliminating check and money order options. The Release also included proposed amendments to Rule 13e-4 under the 1934 Act and Schedule TO, which are used by certain closed-end funds and business development companies to conduct discretionary repurchase offers. The amendments are intended to increase the efficiency of the fee process and enhance the SEC staff’s ability to validate the accuracy of fee payments and offsets for SEC filings. The Release proposes a 42-month transition period for compliance with the proposed Inline XBRL requirements for fund filers.

The Release is available at:


Investment Companies, Regulatory