SEC Proposed Changes on 13F

SEC Proposed Changes on 13F

19 July 2020

Main Contributor: Katie Mogan, IACCP® Vice President, Senior Compliance Consultant


On July 10th, the SEC released a proposal to amend reporting requirements of Form 13F to update the reporting threshold which has not been adjusted in over 40 years.

What is 13F?

Section 13F of the Securities and Exchange Act requires registered investment advisers to file a report with the Commission, via the Edgar system, if the investment adviser has discretion over 13F equity securities in aggregate of $100M or more.

What are the proposed changes to 13F?

With the proposed changes, the SEC intends to reduce the financial and administrative/compliance burden on smaller firms. The proposed changes include:

  1. Increasing the filing threshold of $100M in discretionary-managed aggregated assets to $3.5B,
  2. Requiring the SEC to review and update the threshold (up or down) every five years,
  3. Eliminating the ability to omit holdings of fewer than 10,000 shares (or less than $200,000 in principal amount of convertible debt securities) and less than $200,000 aggregate fair market value,
  4. Requiring managers to report certain numerical identifiers, specifically the filer’s CRD and SEC filing numbers (including the identifiers of other managers included on the form),
  5. Certain technical amendments to modernize reporting and streamline information, and
  6. Amending the instructions for confidential treatment to align the SEC with the standard established by the U.S. Supreme Court in 2019.

What Do You Need to Do?

Right now, nothing, unless you would like to comment on the proposal, in which case you can visit the proposed rule on how to comment. The proposal is out for comment for 60 days.  Once the rule is updated and final, SCS will provide final details so you know what the final changes are and if you must still report.