Deadline Approaching for Filing the Form 13F with the SEC

February 10, 2010

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Is your investment advisor firm required to file quarterly the Form 13F with the SEC?

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 U.S. Securities and Exchange Commission (“SEC”). Since a registered investment advisor firm meets the definition of an institutional money manager, it is subject to this rule when the investment advisor firm exercises investment discretion over $100 million of Section 13(f) securities.

An investment advisor firm that does not currently submit Form 13F reports with the SEC needs to verify that it did not exceed the 13(f) discretion threshold of $100 million at any time during calendar year 2009. To the extent your investment advisor firm exceeded $100 million of Section 13(f) securities any time during 2009, your investment advisor firm will need to file its first Form 13F by February 15, 2010. The Form 13F must report ending values as of December 31, 2009. Your investment advisor firm will then need to submit filings for quarters ending March, June, and September 2010, even if the market value of your Section 13(f) securities falls below the $100 million level.

Finally, 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 2009 must also submit their fourth quarter 2009 reports by February 15, 2010.

Posted by Bryan Hill
Labels: Form 13F