S-X 12-12 currently requires registered investment companies to disclose a complete listing of investments.

For registered investment companies, Regulation S-X is still applicable. In October 2016, the SEC issued the final rule on Investment Company Reporting Modernization. As part of this rule, Articles 6 and 12 of Regulation S-X were amended with a compliance date of August 1, 2017. The amendment states that these articles apply to registered investment companies and business development companies. The amendments largely focus on standardizing disclosures related to derivative investments and require prominent placement within the Schedule of Investments versus being included in the notes to the financial statements as was typically done historically. Additionally, the amendments require additional elements of disclosure for all investments held.

S-X 12-12B permits a registered investment company to include a summary portfolio schedule in its reports to shareholders, provided that the complete portfolio schedule is filed with the SEC on Form N-CSR semi-annually. Refer to Asset Management Advisory 2005-1, Summary Portfolio of Investments, for a Q&A on the summary disclosure rules. The summary portfolio disclosure rules are only applicable to securities of unaffiliated issuers. Disclosure of affiliated securities should comply with S-X 12-14. As noted in the Summary Portfolio Q&A, a separate audit opinion is required on the full portfolio of investments which is filed with the Form N-CSR, if the registrant adopted a summary portfolio for its annual report.

Money market funds are completely exempt from including a portfolio schedule in reports to shareholders, provided that this information is filed with the SEC on Form N-CSR. However, GAAP, as stated in ASC 946-210-50, requires all funds, including money market funds, to provide at least a condensed portfolio in financial statements. FinREC previously concluded that it would not pursue a project to amend the Audit Guide to conform the portfolio requirements to SEC rules. Accordingly, money market funds at this time should provide, at a minimum, a condensed portfolio in the financial statements appearing in shareholder reports in order to issue an unqualified opinion thereon.

The Audit Guide and ASC 946-210-50-1 require that investment companies other than nonregistered investment partnerships should disclose the following, in absence of other regulatory requirements:

ASC 210-50-8 requires that investments in other investment companies are considered individual investments and require disclosures as outlined in ASC 946-210-50-1 (a) though (b) and 50-6.

Entities registered with the CFTC as commodity pools are no longer exempt from the requirements of ASC 946-210. Refer to ASC 946-210-50-4.