Retail Investors Deserve More Timely Access to Fund Portfolio Data

Under current rules, registered investment companies, a $28 trillion industry of largely mutual funds and exchange-traded funds, provide the Commission and investors with periodic portfolio holdings data. The Commission relies on this data to assess trends and risks, and to support its rulemaking, examination, and enforcement efforts.

Institutional and retail investors benefit from access to the same data that can help them make more informed investment decisions.

The current rules impact approximately 70 million US households.

Concerns about whether data provided under current timelines renders it stale, both for oversight and investment decision purposes, are well-founded.

Delayed information in the context of the COVID-19 pandemic, and geopolitical events and other market stresses in recent years, has limited the Commission's timely understanding of the market impacts of these events.

More importantly, investors are left to make decisions with incomplete or outdated information. Data aggregators and other market participants can be a source of some information for investors. And many funds voluntarily post periodic information on their websites or through third parties. But practices vary. The data provided is not standardized, often lacks risk metrics, and may only be available for a fee.

If adopted, reforms that yield more timely fund portfolio information will no doubt help the Commission better assess the impact and risks of market stresses, closer to when they are unfolding.

Relative to the status quo, today's reforms will also offer investors more timely access to data.

But the current framework, where investors gain access to the information much later than the Commission, will remain unchanged. That is, fund information will be made public on a 60-day delay - leaving investors at a significant disadvantage.

In light of this disparity, I urge that Commission staff explore future amendments to this rule so that investors can benefit from more timely access to fund portfolio data.

As I see it, fulfilling the investor protection part of our mission means elevating the interests of investors, retail investors in particular, to the forefront.

Today's reforms fall short of that. But I will support them because, taken together and on balance, these reforms represent an improvement over the current rule.

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