Deadline Approaching for Filing the Form 13F with the SEC

January 12, 2015

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Is your investment adviser 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 adviser firm meets the definition of an institutional money manager, it is subject to this rule when the investment adviser firm exercises investment discretion over $100 million of Section 13(f) securities.

Click here for a list of Section 13(f) securities.

An investment adviser 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 the past calendar year. To the extent your investment adviser firm exceeded $100 million of Section 13(f) securities any time during 2014, your investment adviser firm will need to file its first Form 13F within 45 days of end of the calendar year.  Since the 45th day falls on Saturday, February 14, 2015 and Monday, February 16, 2015 is federal holiday, the filing deadline is Tuesday, February 17, 2015. This first Form 13F must report ending values as of December 31, 2014. Your investment adviser firm will then need to submit filings for quarters ending March, June, and September 2015, 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 2014 must also submit their fourth quarter 2014 reports by February 17, 2015.

Posted by Bryan Hill
Labels: Form 13F