Form 13F Reporting: The $100 Million Test, 45-Day Clock and EDGAR XML

On 17 September 2024 the SEC announced settled charges against 11 institutional investment managers for failing to file Form 13F, the quarterly holdings report required by rule 13f-1 under the Securities Exchange Act of 1934. Nine of them agreed to pay civil penalties totalling more than $3.4 million; the two that self-reported and cooperated were not ordered to pay any penalty. Form 13F reporting applies to any institutional investment manager whose discretionary accounts held at least $100 million of securities on the SEC’s Official List of Section 13(f) Securities (the 13F List) on the last trading day of any month in a calendar year, and each report is due within 45 days of the period it covers.

Three determinations decide the filing long before anyone opens EDGAR: whether the manager exercises investment discretion over the accounts, whether any month-end value in the calendar year reached the threshold, and which manager in a group puts each holding on its Information Table. An error in the first two leaves a whole cycle of four reports unfiled. An error in the third reports holdings twice, or drops them.

The rule text is short. Most of the operating detail, from the valuation date and dollar rounding to the small-position omission and the option conventions, sits in the Special Instructions of the form, in the SEC’s EDGAR Form 13F XML Technical Specification and in the staff FAQ of the Division of Investment Management.

Related reading: Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch

The legal basis of Form 13F reporting: section 13(f), rule 13f-1 and the form itself

Congress enacted section 13(f) of the Exchange Act (15 U.S.C. 78m(f)) in 1975 to increase the public availability of information on institutional holdings, and the Commission adopted rule 13f-1 and Form 13F in 1978. The legal chain has three links, all administered by the Securities and Exchange Commission (SEC):

• Statute: section 13(f) of the Exchange Act. Paragraph (f)(4) is the basis the SEC cites both for publishing the list of reportable securities and for withholding reported information from public disclosure; paragraph (f)(3) lets the Commission exempt managers or securities by rule or order; paragraph (f)(6)(A) defines the institutional investment manager.
• Rule: 17 CFR 240.13f-1. Paragraph (a)(1) sets the $100,000,000 test and the 45-day deadlines, (a)(2) governs amendments, (b) defines investment discretion by reference to section 3(a)(35) of the Act and adds a control rule, and (c) defines section 13(f) securities and ties them to the Commission’s published list.
• Form: Form 13F (17 CFR 249.325), printed as SEC 1685 (07-23) under OMB control number 3235-0006. Its General Instructions restate the rule, its Instructions for Confidential Treatment Requests govern omitted holdings, and twelve Special Instructions set out how each page and column is completed.

The third link is where the working rules live. The valuation date, the nearest-dollar rounding, the small-position omission and the option conventions appear in the form’s Special Instructions and nowhere in the CFR section. A procedures manual that cites rule 13f-1 alone documents the filing duty and none of its mechanics.

The staff FAQ carries a different weight. The Division of Investment Management’s Frequently Asked Questions About Form 13F state that they reflect staff views, are not a rule or regulation, and have been neither approved nor disapproved by the Commission. Several answers are phrased as advice: FAQ 28, for example, says a manager “generally should file” its first report for the December quarter. I read those answers as the staff’s interpretation of the rule’s timing, useful precisely because the rule itself is terse.

Who must report on Form 13F: discretion, the month-end test and the 13F List

Rule 13f-1(a)(1) applies to every institutional investment manager that exercises investment discretion over accounts holding section 13(f) securities with an aggregate fair market value of at least $100,000,000 on the last trading day of any month of any calendar year. Three elements carry the scope.

The manager

The staff FAQ reads the term broadly: it covers entities that invest for their own account, such as banks and insurance companies, and entities that exercise discretion over other people’s accounts, such as investment advisers and bank trust departments. Registration status is irrelevant: a manager that meets section 13(f) must file “regardless of whether it is an SEC-registered investment adviser” (FAQ 5). A foreign manager is in scope when it uses any means of US interstate commerce in its business and meets the threshold (FAQ 4). A natural person who invests only his or her own money does not file; a natural person who manages other people’s money does.

Investment discretion and control

Discretion takes its meaning from section 3(a)(35) of the Exchange Act. FAQ 6 breaks it into two limbs: the manager has the power to determine which securities are bought or sold for the account, or it makes those decisions even though someone else is responsible for the investment decisions. Rule 13f-1(b) then extends discretion up the control chain, deeming a manager to exercise discretion over all accounts over which any person under its control exercises it, so a parent counts its subsidiaries’ discretionary accounts toward its own threshold. The form sets a limit at the other end: a manager of an institutional account, such as a pension fund or an investment company, is not deemed to share discretion with that institution unless the institution actually participated in the investment decision-making (note to Special Instruction 11.b.vi).

The threshold and the 13F List

The test runs twelve times a year. FAQ 27 names the last trading day of each month, January through December, as the measurement points. A manager whose holdings cross $100 million at the end of one month and fall back by the quarter-end has met the threshold for that calendar year, and a test run only at quarter-ends misses that crossing.

Only securities on the 13F List count, and only those are reported. Rule 13f-1(c) defines section 13(f) securities as equity securities of a class described in section 13(d)(1) of the Act that are admitted to trading on a national securities exchange or quoted on the automated quotation system of a registered securities association, and allows the manager to rely on the most recent list the Commission publishes. The staff FAQ describes the list as primarily US exchange-traded stocks, shares of closed-end funds and shares of exchange-traded funds; shares of open-end mutual funds are not on it. The list is updated quarterly and published shortly after each calendar quarter ends, in PDF and, beginning with the fourth quarter of 2025, also as a text file.

Options follow their own rule. A manager reports options only if the options themselves are section 13(f) securities, and for the $100 million test it should consider only the value of the options, not the value of the underlying shares (Special Instruction 10).

Group structures and the consolidation question

Being in scope and putting holdings on a table can sit with different entities. Where two or more managers that each must file exercise discretion over the same securities, only one of them has to report those holdings (General Instruction 2). The manager whose holdings appear elsewhere still files: a 13F Notice when all of its holdings are on another manager’s report, a 13F Combination Report when only part of them are. The reporting manager lists the other managers on whose behalf it files, and FAQ 37 limits that list to managers that share discretion with it and themselves meet the $100 million threshold; the holdings of sharing managers below the threshold are aggregated on the filer’s own report without a listing.

What the report contains: Cover Page, Summary Page and an eight-column Information Table

Special Instruction 1 splits Form 13F into three parts, and the staff treats them as one EDGAR document. FAQ 31 states that a 13F-HR not submitted as one document with all three parts combined is incomplete or otherwise inaccurate and has to be amended.

Cover Page

The Cover Page carries the report date (the last day of the calendar year or quarter, even where the valuation date differs), the amendment box with its number and type, the manager’s name and address, its Form 13F file number and, where the manager has them, its CRD number from the Central Registration Depository or the Investment Adviser Registration Depository and its SEC file number, such as an 801- or 8- number. It also carries the signer’s name, title and telephone number, the report type and, for Notices and Combination Reports, the List of Other Managers Reporting for this Manager. Extra information is allowed only after the signature block, and never on the Summary Page or in the Information Table (Special Instruction 4).

Summary Page

The Summary Page holds three figures: the Number of Other Included Managers, the Information Table Entry Total and the Information Table Value Total. The entry total counts line items, which exceed the issuer count whenever one issuer has several classes or discretion types (FAQ 35). The value total is the sum of Column 4 across all lines (Special Instruction 6.c). A checkbox flags that holdings were omitted under a confidential treatment request, and the numbered List of Other Included Managers closes the page, or the word NONE where the report covers the filer alone.

Information Table

Each line is one issuer, one class and one discretion category. Securities of the same issuer and class held under sole discretion are listed separately from those under shared discretion (Special Instruction 11.a). Shared-defined covers discretion shared between controlling and controlled companies, between an investment adviser and the investment companies it advises, or between an insurance company and its separate accounts; any other sharing is shared-other. Each shared category is split again between discretion shared with a manager included in the report and discretion shared with anyone else, each segregation on its own line. FAQ 38 allows aggregation within a class where discretion is sole, or shared with someone who has no independent filing obligation, but options and convertible debt of the same issuer go on separate lines.

Column 8 is easy to overstate. Voting authority is measured separately from discretion, and the form deems a manager with authority only over routine matters, such as selecting an accountant, an uncontested election of directors or approving an annual report, to have no voting authority for Form 13F purposes. Authority over non-routine matters, such as a contested election, a merger or a sale of substantially all assets, is what counts. Voting authority shared only in the way that would make discretion shared-defined is reported as sole.

Values are US dollars, amounts are share counts or principal, and the XML schema types both as integers. A negative or net position has no place on the table; the staff’s treatment of short positions and written options appears in the FAQ section below. The table records positions only, with no trade-level fields, which separates it from regimes built on individual transactions, such as the one in our MiFIR transaction reporting guide.

Special Instruction 9 lets a manager omit a holding if, on the period end date, it holds fewer than 10,000 shares (or less than $200,000 principal amount of convertible debt) and less than $200,000 aggregate fair market value, with any option holdings limited to purchasing only such amounts. Both conditions must hold, and the omission is optional: FAQ 39 confirms a filer may still include such positions. The instruction speaks of holdings “otherwise reportable”, so I read it as relief from listing that leaves the $100 million computation untouched, since rule 13f-1(a) measures all section 13(f) securities.

Form 13F deadlines: the December-quarter start, the 45-day clock and the holiday roll

Rule 13f-1(a)(1) fixes the calendar: a report within 45 days after the last day of a calendar year in which the threshold was met, and within 45 days after the last day of each of the first three calendar quarters of the following year. The reference dates are therefore 31 December, 31 March, 30 June and 30 September, with nominal due dates of 14 February, 15 May, 14 August and 14 November.

The first applicable reference date is the December quarter-end of the calendar year in which the manager first meets the threshold. FAQ 29 works through a manager that first reaches $100 million on the last trading day of July: its first report covers the quarter ended in December of that year and is due by 14 February, and the March, June and September reports of the following year come next. A July crossing therefore produces no report for the September quarter of the same year. Once the cycle starts, rule 13f-1(a)(1), as FAQ 25 reads it, requires all four filings even if the value later falls below $100 million, and the month-end values during that following year decide whether the next December report is due.

Weekends and holidays move the date. FAQ 25, citing Rule 0-3(a) under the Exchange Act, states that a deadline falling on a Saturday, Sunday or holiday moves to the first business day thereafter. The staff’s example is the report for 31 December 2025: 14 February 2026 was a Saturday and 16 February a holiday, so the deadline became Tuesday 17 February 2026. FAQ 25 publishes the computed dates for quarters ending in 2026 to 2028:

Two further points set the clock. The valuation point is the close of trading on the last trading day of the quarter (Special Instruction 8), while the period end date on the Cover Page stays the calendar quarter-end even when that day is not a trading day (Special Instruction 2). And the staff grants no extensions: FAQ 26 says not to ask for one, to file as soon as possible after a missed deadline, and not to submit a misleading or incorrect filing.

Amendments run on their own timing. Amendments that follow a denial or expiry of confidential treatment carry a short fixed deadline, covered under the caveats below. For an error discovered later, FAQ 58(a) says the manager should promptly amend; rule 13f-1(a)(2) sets no day count.

Submission through EDGAR: report types, XML documents and filer access

Form 13F is filed electronically on EDGAR. FAQ 30 points a manager holding a hardship exemption under rule 201 or 202 of Regulation S-T to a mailing address for a paper report; otherwise, public reports and confidential treatment requests are filed through EDGAR. The report type decides the EDGAR submission type and which parts are filed:

Confidential treatment requests travel separately as 13F-CTR, or 13F-CTR/A for an amendment.

There are two ways to build a filing. A manager can complete the online Form 13F on the EDGAR Filing website and attach the Information Table as an XML document, or construct the entire submission in XML under the technical specification and transmit it. Either way, the Information Table must conform to the schema file eis_13FDocument.xsd, open with the namespace the specification prescribes, and carry no namespace prefixes on its elements. A 13F-HR may enclose only one document, the Information Table, and a 13F-HR without it is suspended; a 13F-CTR may carry two, the Information Table and the request letter. Attached file names may run to 32 characters including the .xml extension, must start with a letter, and may use only lowercase letters, digits and at most one underscore, one hyphen and one period.

Access runs through EDGAR Next. The SEC’s EDGAR Next page states that individuals acting for a filer log in with individual Login.gov credentials and multifactor authentication, that legacy login methods have been discontinued, and that enrollment has closed; a filer that did not enroll applies for access by submitting a Form ID on the EDGAR Filer Management website. The staff FAQ asks new 13F filers to select the applicant type “Institutional Investment Manager (Form 13F Filer)” on Form ID. The XML submission itself still carries the filer’s CIK and CIK confirmation code in its credentials block.

The Form 13F file number, with its 028- prefix, is assigned only after the first filing; FAQ 12 suggests a new filer include a notification tag in the EDGAR submission header to receive it. The signature is typed, and FAQ 21 notes that rule 302(b) of Regulation S-T requires a manually or electronically signed authentication document behind it, retained for five years.

Validation in EDGAR: suspense conditions, warnings and what acceptance does not prove

EDGAR checks a Form 13F against the four schema files in the technical specification package (eis_13F_Filer.xsd, eis_13FDocument.xsd, eis_Common.xsd and eis_stateCodes.xsd) and against business rules the schemas cannot express. The specification recommends validating against the schema files before filing, and notes that a submission meeting every schema constraint can still be SUSPENDED or BLOCKED; EDGAR verifies, for instance, that each CIK and CCC pair is valid. Table 6-1 of version 2.0 grades the errors it lists as SUSPENDED or WARNING, states that the list is not exhaustive, and includes these conditions:

The data-type rules apply to every line-level field. Integer fields, which include Column 4, the Column 5 amount, the three voting authority figures and the Summary Page totals, accept only the digits 0 to 9: no commas, decimal points, dollar signs, minus signs or parentheses. The choice lists are case sensitive: SH or PRN; Put or Call; SOLE, DFND or OTR. The option values trap anyone working from the printed instructions, because Special Instruction 10 and FAQ 44 write the designations as PUT and CALL while the schema accepts only “Put” and “Call”, the mixed case the form’s Column 5 instruction uses.

Length limits bite too: 9 characters for the CUSIP, 12 for the FIGI, 150 for the issuer name and for the title of class, 16 digits for value and amount, and up to 250,000 Information Table rows per document. All three voting authority elements are mandatory in the schema for every line, including lines for reported call options, where Special Instruction 10 excuses only the printed Column 8 entry. The SEC’s quick reference guide for building the table in Excel says to enter zero where there is no value.

Acceptance proves less than it appears to. FAQ 30 states that an acceptance message does not address the substantive accuracy or correctness of the filing, and tells filers to review the accepted Form 13F on the SEC’s website for completeness and column formatting. Several checks fall to the filer alone. Table 6-1 lists no reconciliation between the Summary Page value total and the Column 4 entries, although Special Instruction 6.c requires the two to agree, and no schema can test whether a security belongs on the 13F List, whether a discretion code is right, or whether an omitted small position met both limbs of Special Instruction 9.

Corrections come in two forms. A restatement resubmits the entire report as corrected and supersedes the original (FAQ 58(b)); an amendment that adds new holdings carries only the omitted securities and supplements the original (FAQ 58(c)). Rule 13f-1(a)(2) requires the complete text of the Form 13F for every amendment other than one reporting only holdings not previously reported in a public filing for the same period, and requires amendments to be numbered sequentially.

Caveats and interactions: confidential treatment, bank copies, Form N-PX and Form SHO

Form 13F applies one template to every filer: a manager at the threshold completes the same table as one many times larger. The reliefs are the small-position omission, confidential treatment, the Regulation S-T hardship exemption and the Commission’s power under section 13(f)(3) to exempt managers or securities by rule or order.

Confidential treatment

Under section 13(f)(4), as the form’s instructions describe it, the Commission may prevent or delay public disclosure of reported information in accordance with the Freedom of Information Act, and shall not disclose information identifying securities held by the account of a natural person or an estate or trust other than a business trust or investment company. Holdings of that second kind must go through the confidential treatment procedure. For commercial holdings, the request must cover, among other points, the investment strategy, why disclosure would be likely to reveal it, why that revelation would be premature and the harm to the manager, and the period requested may not exceed one year from the date the Form 13F was due. Open risk arbitrage positions not covered by an earlier request have a shorter route: written good-faith representations made at filing lead the Commission to accord confidential treatment automatically for up to one year. Requests are filed on EDGAR, and the public report ticks the Summary Page box and states that confidential information has been omitted and filed separately.

The protection ends on a clock. Unless a de novo request is filed at least 14 days before the expiry date, the holding goes public: within six business days of a denial or an expiry, the manager files an amendment that adds new holdings entries, which must not be a restatement, with the prescribed legend at the top of the Cover Page.

Bank copies

General Instruction 3 adds a recipient for one type of manager. A bank whose deposits are insured under the Federal Deposit Insurance Act must file a copy of every Form 13F report with its appropriate regulatory agency, as section 13(f)(5) requires, either electronically with the confidential access codes removed or blanked out, or on paper. Bank holding companies can also have Federal Reserve reporting duties, such as the report covered in our FR Y-12 reporting guide, each with its own instructions.

Form N-PX say-on-pay votes

Rule 14Ad-1 (17 CFR 240.14Ad-1) attaches an annual report to the Form 13F obligation. Subject to first-year and final-year adjustments covered in the FAQ below, every institutional investment manager required to file reports under section 13(f) files Form N-PX by 31 August each year, for the 12 months ended 30 June, recording its votes under sections 14A(a) and (b) of the Exchange Act on executive compensation matters for each security over which it exercised voting power. The rule defines voting power to include the ability to determine whether to vote a security or to recall a loaned security, a definition drafted independently of Column 8’s routine and non-routine test.

Form SHO short-position reporting

Rule 13f-2 and Form SHO use the statutory definition of institutional investment manager and the investment discretion definition in rule 13f-1(b), with position-based thresholds of their own. For an equity security of a class registered under section 12 of the Act, or whose issuer must file reports under section 15(d), the trigger is a monthly average gross short position at the close of regular trading hours of $10 million or more, or of 2.5% or more of shares outstanding; for other equity securities, it is a gross short position worth $500,000 or more at the close of regular trading hours on any settlement date in the month. Reports are due within 14 calendar days after month-end, and paragraph (a) contains no reference to the $100 million Form 13F threshold. Compliance is deferred by exemptive order: on 3 December 2025 (Release No. 34-104303) the Commission granted a temporary exemption until 2 January 2028, after the Fifth Circuit remanded the rules without vacatur on 25 August 2025, so the first Form SHO reports would cover January 2028 and be due within 14 calendar days after that month ends.

The September 2024 settlements show a further overlap: two of the eleven managers were also charged with failing to file Form 13H, a separate filing obligation under its own rule.

Changes to Form 13F: from ASCII text to XML, the 2022 amendments and the moving parts since

• 1975 and 1978: Congress enacts section 13(f); the Commission adopts rule 13f-1 and Form 13F (43 FR 26705, 22 June 1978). The $100 million threshold has not been adjusted since.
• 20 May 2013: text-based ASCII filings are discontinued. Filers either use the online form with an XML Information Table or construct the whole filing in XML.
• 10 July 2020: the Commission proposes raising the threshold to $3.5 billion, removing the small-position omission and requiring a staff review of the threshold every five years (Release No. 34-89290). The rule in the 2025 CFR edition and the current form still state $100,000,000 and still carry the omission.
• 23 June 2022: Release No. 34-95148 (87 FR 38943, 30 June 2022), effective 29 August 2022, moves confidential treatment requests onto EDGAR, mandatory from 28 February 2023. The Form 13F amendments, effective 3 January 2023, add the CRD and SEC file numbers, the optional FIGI, the Summary Page confidential treatment checkbox and revised confidential treatment instructions, and switch values from the nearest thousand dollars to the nearest dollar. FAQ 62 applies the updated form to every report filed on or after 3 January 2023, including amendments for earlier quarters. Technical specification version 1.7, released the same day, adds the crdNumber and secFileNumber elements.
• 1 July 2024: rule 14Ad-1 takes effect, with the first manager Form N-PX reports due by 31 August 2024, covering 1 July 2023 to 30 June 2024.
• EDGAR Next: Login.gov individual credentials and multifactor authentication replace legacy logins for every EDGAR filer.
• Fourth quarter of 2025: the 13F List is published as a text file alongside the PDF.
• 3 December 2025: the Commission extends the temporary Form SHO exemption described above.
• 15 December 2025: technical specification version 1.9 adds warning conditions for the fileNumber and confirmingCopyFlag elements.
• 14 September 2026: technical specification version 2.0 renames the Cover Page element provideInfoForInstruction5 to provideInfoForInstruction, the flag for the question whether the filer provides explanatory information, for example under Special Instruction 4. Our note on EDGAR Filer Manual Version 78 covers the Filer Manual update adopted for the same EDGAR Release 26.3 deployment on 14 September 2026.

None of the SEC sources cited here announces a pending amendment to rule 13f-1 or to Form 13F itself. Between quarters, a new technical specification version can still change element names in a filer-built XML file, as version 2.0 did.

Frequently Asked Questions

Do ADRs and other shares of foreign issuers count toward the threshold and the report?

Only if they are on the 13F List. FAQ 40 says shares of a foreign issuer are reported only if they trade on a United States exchange or are quoted on the NASDAQ National Market System, which excludes “pink sheet” ADRs, and that shares trading on non-United States exchanges are not reported on Form 13F.

We lend securities over quarter-end. Who reports them?

The lender. FAQ 42 says a manager reports securities it owns and has loaned to a third party, and the borrower does not report them.

A purchase executes on the last trading day of the quarter and settles afterwards. Is it in the report?

Yes. FAQ 8b answers the trade-date or settlement-date question with “The trade date”, so a position bought on the last trading day of the quarter is part of the quarter-end holding even though it settles in the next quarter.

Can short positions or written options be netted against the long position?

No. FAQ 41 says short positions are not included and are not subtracted from long positions in the same security; only the long position is reported. FAQ 43 applies the same treatment to put and call options the manager has written and says the same is true for warrants, while warrants the manager holds that are on the 13F List may be reported. Purchased options that are themselves on the 13F List go on separate lines, stated in terms of the underlying securities.

Our group controls a listed company. Do those shares count toward the parent’s Form 13F?

Rule 13f-1(c) carves them out, with a condition. Where a person controls the issuer of a class of section 13(f) securities, those securities are not section 13(f) securities with respect to the controlling person, provided that the person does not otherwise exercise investment discretion over accounts with a fair market value of at least $100,000,000 within the meaning of paragraph (a). Once the controller’s other discretionary accounts meet that threshold, the carve-out falls away.

When does Form N-PX start and stop for a manager entering or leaving Form 13F?

Rule 14Ad-1(b) excuses the 12-month period ending 30 June of the calendar year in which the manager’s initial Form 13F is due, an initial filing being any quarterly report where none was required for the preceding quarter. At the other end, paragraph (c) requires a final Form N-PX covering 1 July to 30 September of the calendar year in which the final Form 13F is due, filed by 1 March of the following year; votes at meetings after 30 September of that year are not reported.

Can a manager reuse its existing EDGAR CIK for Form 13F?

It depends on what the CIK is used for. FAQ 18 requires a separate CIK, obtained through a new Form ID, where the existing CIK belongs to a registered investment adviser, broker-dealer or transfer agent; where the entity has used its CIK only for Schedule 13D or 13G filings, it files Form 13F under the same CIK and access codes and does not send another Form ID.

Related Articles

• Form PF Reporting: Thresholds, Deadlines and the July 2027 Form Switch: the SEC’s confidential private fund return for registered advisers, with its own thresholds, clocks and filing system.
• EDGAR Filer Manual Version 78: Form 1, ANE Notices and the XBRL Move: the Filer Manual update adopted for EDGAR Release 26.3, which moves XBRL technical rules to the EDGAR XBRL Guide.
• FR Y-12 Reporting: Thresholds, Schedules and the 45-Day Deadline: the Federal Reserve’s report of holding company equity investments in nonfinancial companies.
• MiFIR Transaction Reporting: Complete Guide to Article 26 Compliance: the EU regime that reports individual transactions in financial instruments.
• AIFMD II Annex IV Reporting Changes: what the directive changes for the EU supervisory return that alternative investment fund managers file.

Key Takeaways

• Treat the first month-end at or above $100 million as the trigger for a four-report cycle that opens with the December quarter of that year.
• Settle each group entity’s report type (Holdings Report, Combination Report or Notice) before quarter-end, and agree which manager carries each shared holding.
• Map discretion and voting at source: SOLE, DFND or OTR per line, the other-manager numbers, and sole, shared and none voting counts, with routine-only voting authority recorded as none.
• Validate the Information Table against eis_13FDocument.xsd from the current specification before upload, with integer values and the case-sensitive Put and Call designations.
• After acceptance, reconcile the published Summary Page value total to the Column 4 sum, and correct errors by full restatement, or by an add-only amendment for omitted holdings.
• Diary the dependent dates: confidential treatment renewals at least 14 days before expiry, the six-business-day amendment after a denial or expiry, Form N-PX by 31 August, and the Form SHO exemption ending on 2 January 2028.

Sources and References

• Securities Exchange Act of 1934, section 13(f), 15 U.S.C. 78m(f): uscode.house.gov
• Code of Federal Regulations, 17 CFR 240.13f-1, Reporting by institutional investment managers of information with respect to accounts over which they exercise investment discretion (4-1-25 edition): govinfo.gov (PDF)
• Code of Federal Regulations, 17 CFR 240.13f-2, Reporting by institutional investment managers regarding gross short position and activity information (4-1-25 edition): govinfo.gov (PDF)
• Code of Federal Regulations, 17 CFR 240.14Ad-1, Report of proxy voting record (4-1-25 edition): govinfo.gov (PDF)
• SEC, Form 13F, Information Required of Institutional Investment Managers Pursuant to Section 13(f) of the Securities Exchange Act of 1934 and Rules Thereunder, SEC 1685 (07-23): sec.gov (PDF)
• SEC Division of Investment Management, Frequently Asked Questions About Form 13F: sec.gov
• SEC, Official List of Section 13(f) Securities: sec.gov
• SEC, EDGAR Form 13F XML Technical Specification, version 2.0 (September 2026), with schema files: sec.gov (ZIP)
• SEC, EDGAR Technical Specifications (Form 13F version history, including versions 1.7, 1.9 and 2.0): sec.gov
• SEC, Adoption of Updated EDGAR Filer Manual, Release No. 33-11438 (14 September 2026, effective 6 October 2026): sec.gov
• SEC, Quick Reference Guide: How to Create an XML Information Table for Form 13F Using Excel: sec.gov (PDF)
• SEC, EDGAR Next: Improving Filer Access and Account Management: sec.gov
• SEC, Electronic Submission of Applications for Orders Under the Advisers Act and the Investment Company Act, Confidential Treatment Requests for Filings on Form 13F, and Form ADV-NR; Amendments to Form 13F, Release No. 34-95148, 87 FR 38943 (30 June 2022): Federal Register 2022-13936
• SEC, Enhanced Reporting of Proxy Votes by Registered Management Investment Companies; Reporting of Executive Compensation Votes by Institutional Investment Managers, Release Nos. 33-11131 and 34-96206: sec.gov (PDF)
• SEC, Order Granting Temporary Exemptive Relief From Compliance With Rule 13f-2 and Form SHO, Release No. 34-104303 (3 December 2025), Federal Register of 8 December 2025: Federal Register 2025-22158 (PDF)
• SEC press release 2020-152, SEC Proposes Amendments to Update Form 13F for Institutional Investment Managers (10 July 2020): sec.gov
• SEC press release 2024-135, SEC Charges 11 Institutional Investment Managers with Failing to Report Certain Securities Holdings (17 September 2024): sec.gov

The Form 13F workpaper to close each December

The control that decides everything else is the month-end threshold workpaper: twelve valuations of 13F List holdings across every discretionary account in the group, the controlled-issuer carve-out applied with its condition, and the result signed off when the year closes. If any month-end reached $100 million, the December report goes on the calendar with its 45-day deadline, moved to the next business day where 14 February falls on a weekend or holiday.

Disclaimer: The information on RegReportingDesk.com is for educational and informational purposes only. It does not constitute legal, regulatory, tax, or compliance advice. Always consult your compliance officer, legal counsel, or the relevant supervisory authority for guidance specific to your institution.