SEC’s Division of Investment Management Issues ADI 2025-15 on Website Posting Requirements

SEC’s Division of Investment Management Issues ADI 2025-15 on Website Posting Requirements

By Ez-XBRL Team 31 January, 2025
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31 January 2025

The SEC’s Division of Investment Management’s Disclosure Review and Accounting Office (DRAO) has published ADI 2025-15, highlighting key issues and reminding registrants of their obligations regarding website postings for various fund types, including mutual funds, ETFs, and money market funds (MMFs).

This guidance comes after DRAO’s recent review of website disclosure requirements under SEC rules and exemptive orders. The staff observed several concerns related to summary prospectuses, ETFs, and MMFs, urging registrants to ensure full compliance with online posting obligations.

Key highlights include:

  • Summary Prospectuses: Mutual funds, ETFs, and variable products using summary prospectuses must post certain documents online, such as prospectuses, statements of additional information (SAI), and annual reports. The website address must be direct and clear, ensuring investors can easily access the necessary information.
  • ETFs: Under Rule 6c-11, ETFs must disclose daily holdings, market prices, premiums/discounts, and other key metrics. The SEC urges ETFs to update these disclosures regularly and ensure clarity in presenting information like the 30-day median bid-ask spread.
  • MMFs: MMFs must post detailed portfolio holdings, net asset values, and other fund data. The DRAO observed some MMFs failing to provide the required links to Form N-MFP filings, reminding them of their ongoing obligations.

The staff urges all registrants to revisit their website disclosures to ensure they meet the SEC’s standards, thus supporting transparency and providing investors with the information needed for informed decision-making.