SEC Filing Updates: What to Know About Amendments to Form 13F
The U.S. Securities and Exchange Commission has updated its electronic data gathering, analysis, and retrieval system to implement one of the largest sets of changes to Form 13F filing requirements in years.
The EDGAR 22.4.1 release on January 3, 2023, introduced amendments to Form 13F to enhance what institutional investment managers disclose about their securities holdings:
- Most significantly, it requires filers to round security holding values to the nearest dollar rather than to the nearest thousand dollars
- This update also allows for new, optional identifiers for securities and reporting managers
- This immediately impacts all 13F reports for the quarter ending December 31, 2022, including amendments to previous reports
- In addition, confidential treatment requests are now required to be submitted electronically via EDGAR
I’ll summarize more of the changes below, but the SEC has also published the following materials to help with compliance:
What to know when preparing your 13F
The changes to Form 13F include:
- Two new fields for the Filer and Other Reporting Managers, primarily Investment Advisors:
- CRD Number (if applicable)
- SEC File Number (if applicable)
- If the “Confidential Treatment Requested” filing option is checked, a notice will appear on the HTML preview for form types 13F-HR and 13F-HR/A indicating “Confidential information has been omitted from the public Form 13F report”
- SEC Column 3 in the Information Table was updated to allow a new optional field for reporting a security's FIGI value (FIGI is Financial Instrument Global Identifier, a 12-character alphanumeric value that may be obtained from openfigi.com)
- SEC Column 4 “Value” in the Information Table was updated to accept up to 16 digits, and filers must comply with the new requirement to enter values rounded to the nearest dollar, instead of values previously reported in thousands
- “Other Managers” information was updated to optionally include the Manager's CRD and SEC File Number values, if available. The SEC notes that “if a manager is filing a Form 13F notice report on Form 13F-NT, the manager must include the CRD number and SEC file number, if any.” The CRD and SEC File Number for an IA manager may be obtained from adviserinfo.sec.gov
- 13F-CTR/A was updated to include a “De Novo Request” field
All Form 13F reports filed on or after January 3, 2023, must use the updated Form 13F. The SEC requires that even an amendment to a Form 13F for the quarter that ended March 31, 2022, that is filed today would use the updated Form 13F.
Filers may have noticed the new FIGI column in the Information Table will require adjustments to your internal reporting processes, since the Value and subsequent columns are shifted by one column to the right. Workiva has an updated spreadsheet template to provide filers, along with assistance with this EDGAR update.
Finally, filers wishing to request confidential treatment for their 13F reports are now required to submit their filings electronically, including de novo requests, using the 13F-CTR or 13F-CTR/A form types. These form types also require a confidentiality request letter to be attached to the filing in PDF format.
Final thoughts on EDGAR 22.4.1
The EDGAR 22.4.1/Final Rule 34-95148 updates to 13F are significant, and the precise implementation dates of the requirements may be confusing, even for seasoned filers and filing agents. The Workiva SEC reporting solution is fully updated to support the 13F changes, and our support team has the resources to assist you with an easy, successful, and regulatory compliant filing.
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