SEC Form 13F Fund Manager Reports

SEC Form 13F Fund Manager Reports

On 10 July 2020, SEC proposed rules on form 13F for fund report of equity.

  • SEC proposed amendments to update form 13F for institutional investment managers.
  • Amend reporting threshold to reflect equities markets, not been adjusted for 40 years.

Form Use and Background

  • SEC Rule 13(f) requires a manager to file a report with SEC, if the manager exercises investment discretion with respect to accounts holding equity securities over threshold.
  • Aggregate fair market value on last trading day of any month in year, at least $100mn.
  • Form gives SEC data, from large managers, on their investment activities and holding.
  • Data used to assess manager influence and impact, maintain fair and orderly markets.

2020 Threshold Changes

  • Raises reporting threshold to $3.5bn, from $100mn reflecting market value of equities.
  • Increase in thresholds, aims to reduce the unnecessary burdens on smaller managers.
  • While retaining disclosure, of over 90% of dollar value of holdings data currently filed.
  • Rule would direct SEC staff to review form 13F reporting thresholds, every five years.
  • Commissioner Herren Lee disputed projected cost savings, concern lost transparency.

Other Changes

  • Eliminated ability of managers to omit small positions, to improve quality of data filed.
  • Require managers to report numerical identifiers, for usability of information provided.
  • Use number assigned by FINRA central registration depository (CRD), or by the IARD.
  • Amend instructions requests related to confidential treatment of Form 13F information.


  • 60-day comment period, following pending publication of rules in the federal register.