Published on Sep 25th, 2024 |

VIGILANT INSIGHTS

Introduction

Multiple Firms were fined a combined $3.4 million in penalties for failing to file Form 13F in a timely manner.

Form 13F is a quarterly filing required by Firms that have at least $100 million AUM that are considered “13(f) securities” under the Exchange Act. These filings are due 45 days after the end of each calendar quarter.

Vigilant Director, Michael Hogan, IACCP, MSJ, was quoted in a recent FundFire article discussing the implications of this recent enforcement.

What Happened?

  • 11 Institutional Investment Managers were charged on September 17th, 2024.
  • Many of the Firms took years to file once they crossed the $100 million threshold, others took over a decade.
  • Two Firms received no financial penalty because they self-reported.
  • The SEC stated that these filings are taken very seriously, because accurate and timely information is required to protect the integrity of securities markets.

Michael Hogan Insights

Michael discusses how these charges demonstrate the renewed focus on Form 13F filings by the SEC.

The accuracy and timeliness of regulatory filings is a topic of inquiry during routine exams and sweeps.

Michael mentions how Form 13F requirements are not a new topic, and they have not had any amendments or new rules adopted recently.

Vigilant's Conclusion

Vigilant’s Conclusion

Failing to submit regulatory filings in a timely manner is low-hanging fruit for SEC enforcement.

It is vital that Firms be sure that they are aware of the requirements, especially if they find their AUM growing quickly. Partnering with an experienced compliance Firm is one way to limit the risk of missing important filings.

Reach out today with any questions you may have.

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