Countdown to Compliance with Tailored Shareholder Report Requirements: Key Considerations

December 6, 2023

In October 2022, the Securities and Exchange Commission (SEC) adopted amendments that will significantly alter the content, format and presentation of annual and semi-annual shareholder reports used by investment companies, including mutual funds and exchange-traded funds (collectively, funds) registered on Form N-1A (Amendments).1 As discussed in a previous S&K Client Alert, the Amendments will result in a new “tailored shareholder report” (TSR), a concise and visually engaging report that is better designed to meet the informational needs of retail investors. The TSR will be much shorter than current shareholder reports; each share class of each fund will have a separate TSR; and some information in current shareholder reports will not be permitted in the TSR and, instead, will be moved to Form N-CSR and made available on a website.

Complying with the Amendments is not merely an exercise in populating a generic template TSR. Rather, given the scope and nature of the Amendments (covering the TSR, N-CSR and website availability), funds should devote sufficient time to obtain input from various personnel – including operations, IT/systems, investor relations, marketing, finance, compliance and legal – and potentially service providers such as fund administrators, technology firms, printers, intermediaries and outside counsel.

While the Amendments create compliance and operational challenges for funds, they also create opportunities for funds to holistically rethink and refresh their investor communications in order to improve shareholder engagement. With less than eight months until the July 24, 2024 compliance date,2 funds should now be considering how they will meet this objective. We summarize some key considerations in the Client Alert at the link below.

If you have any questions regarding the matters covered in this e-mail, please contact any member of our Registered Funds Group.



1      See Tailored Shareholder Reports for Mutual Funds and Exchange-Traded Funds; Fee Information in Investment Company Advertisements, Release No. IC-34731 (Oct. 26, 2022), available at (Release).

2      The Amendments became effective on January 24, 2023, and the compliance date is July 24, 2024. Therefore, any shareholder report actually transmitted to shareholders on or after July 24, 2024 must satisfy the TSR requirements. Given the requirement to transmit shareholder reports within 60 days after period end, most funds will likely begin using the TSR format for shareholder reports covering periods ending after April 30, 2024, unless they accelerate their reporting process and transmit shareholder reports prior to July 24, 2024.