SEC Form 13F Rule Changes from 2023

Overview

On Jan. 3, 2023, the SEC updated the EDGAR system to implement changes related to Form 13F, which is filed by Institutional Investment Managers. This follows the SEC adopting a new final rule on June 23, 2022 to mandate the electronic filing of confidential treatment requests on Form 13F and implement content changes to 13F submissions.

The SEC requires Form 13F to be filed by Institutional Investment Managers with a minimum of $100 million in assets under management. This report discloses equity holdings and must be filed within 45 days following the conclusion of every quarter. Mandated by Congress, Form 13F was started in 1975 to boost investor confidence in public companies. To this day, investors often look at these filings to help inform their own investment strategies.

It is critical for 13F filers to be prepared for these new technical requirements, including the cover and information table changes.

SEC Form 13F changes impact period ending Dec. 21, 2022 filings due by Feb. 13, 2023

Information Table updates for 13F-HR (Holdings Report) and 13F-CTR (Confidential Treatment Request):

In Column 3, a new column labeled FIGI is included adjacent to CUSIP
- FIGI, which stands for Financial Instrument Global Identifier, is a global identifier for securities
- This field is currently optional; however, it may be required in the future
In Column 4, the value being calculated at the close of trading on the last trading day of the calendar year or quarter, as appropriate, must be updated to reflect the value to the nearest dollar
- This is a change from the previous requirement which allowed rounding to the nearest dollar in thousands
- In connection with this requirement, the SEC increased the character limitation from 12 digits to 16 digits
- The total on the Summary Page will also be listed in the nearest dollar

Cover updates for Form 13F-HR, 13F-NT (Notice) and 13F-CTR:

Addition of CRD Number and SEC File Number for any investment managers included on the form
- This includes any Other Manager Reporting for the manager or Other Included Managers who may be reporting on the same Form 13F
- These fields are currently optional
  - Filer:

Institutional Investment Manager Filing This Report

- List of Other Managers Reporting for this Manager:

List of Other Managers Reporting for this Manager-1

- List of Other Included Managers:

Additional Resources and Information:

Form 13F: https://www.sec.gov/files/form13f.pdf
Final Rule: https://www.federalregister.gov/documents/2022/06/30/2022-13936/electronic-submission-of-applications-for-orders-under-the-advisers-act-and-the-investment-company
EDGAR Filer Manual: https://www.sec.gov/edgar/filermanual
13F EDGAR Technical Specifications: https://www.sec.gov/info/edgar/specifications/form13fxmltechspec
Frequently Asked Questions About Form 13F: https://www.sec.gov/divisions/investment/13ffaq
Toppan Merrill Client Worksheet(s):

If you have questions about the new 13F filing rule changes or simply want to speak with a Toppan Merrill expert about getting started with SEC Connect, the SaaS platform for Form 13F compliance, connect with us via [email protected] or by phone at 800.688.4400.

Jennifer Froberg - Sr SEC Product Specialist

With over 15 years of industry experience in the SEC regulatory landscape, Jennifer supports and advises clients in how to get their filings right. Part of a Toppan Merrill team of EDGAR experts who provide practical compliance expertise in a variety of subjects, Jennifer focuses on analyzing the scope of SEC rulemaking, where the agency is headed and how regulatory changes will impact the filers, investors and the market. She has a particular focus on structured data and ESG initiatives.

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