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.
Does your firm need to begin preparing and/or continue submitting Form 13F to be in compliance with Section 13(f) of the Securities Exchange Act of 1934? If you are unsure or would like to learn more about the reporting of Section 13(f) securities please join us for our webinar, “Filing 13F Reports”, next Thursday, January 8, 2009 at 12:00 CST. The registration fee for our webinar is $59.95. The goal of our webinar is to help attendees better understand when a registered investment adviser is required to file the Form 13F. We will discuss how a filing firm can establish an EDGAR account, examine what is and what is not a Section 13(f) security, and then closely review the Form 13F instructions.
If you are unable to attend the webinar, please contact us to learn more about our Form 13F consulting services which focus on helping registered investment advisors understand the Section 13(f) requirements and then help your investment advisor to determine whether your firm is required to file a Form 13F. Through strategic alliances with EDGAR filing firms, we can help your firm establish an EDGAR account and timely submit all required reports.
Posted by Bryan Hill
Labels: Form 13F