According to Section 13(f) of the Securities Exchange Act of 1934, an institutional money manager that exercises investment discretion over $100 million of Section 13(f) securities must submit quarterly 13F reports to the SEC. Registered investment advisors meet the definition of institutional money manager and are therefore subject to this rule when they exercise investment discretion over $100 million of Section 13(f) securities. A registered investment advisor that does not currently submit Form 13F reports with the SEC needs to make sure it did not exceed the 13(f) discretion threshold of $100 million at any time during calendar year 2008. To the extent your firm did exceed $100 million of Section 13(f) securities any time during 2008, your firm will need to file its first Form 13F by February 14, 2009. The Form 13F must report ending values as of December 31, 2008. Your firm will then need to submit filings for quarters ending March, June, and September 2009, even if the market value of your Section 13(f) securities falls below the $100 million level. Current Form 13F filers that exceeded $100 million of discretionary 13(f) securities on the last trading day of at least one month during the year 2008 must also submit their fourth quarter 2008 reports by February 14, 2009.
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