As our readers know, I spend a great deal of my time traveling the country preparing advisory firms for SEC regulatory examinations. One of the issues on the exam, Form 13F, is too often misunderstood, leaving many firms in violation of regulatory filing requirements. So what is Form 13F, and to whom does its reporting obligations apply?
In short, Form 13F is a quarterly report of equity holdings by investment advisors who maintain discretionary authority over $100 million or more of exchange-listed equity securities. The SEC describes Form 13F as follows:
Institutional investment managers must use Form 13F for reports to the Commission required by Section 13(f) of the Securities Exchange Act of 1934 and Rule 13f-1 thereunder. Rule 13f-1(a) provides that every manager who exercises investment discretion with respect to accounts holding Section 13(f) securities, as defined in Rule 13f-1(c), having an aggregate fair market value on the last trading day of any month of any calendar year of at least $100 million shall file a report on Form 13F with the Commission within 45 days after the last day of such calendar year and within 45 days after the last day of each of the first three calendar quarters of the subsequent calendar year.
Except for the initial filing, 13F filings are due 45 days after the end of each quarter. If the date falls on a weekend or holiday it is typically pushed forward to the first business day thereafter. For example, the Dec. 31 13F report is due on Feb. 14.
