Published on Jun 28th, 2022 |

Brief Introduction

On Thursday, June 23rd, the SEC adopted amendments to require certain documents filed by investment advisers, institutional investment managers, and certain other entities to be filed or submitted electronically.

Form 13F was an important focus as the amendments allowed it to be modernized making technical amendments which enhances the information provided.

What are the overall efficiencies created from this new Rule?

  • Transparency, efficiency, and operational resiliency by modernizing how information is filed or submitted to the Commission and disclosed to the public.
  • Easy accessibility on websites and to the public.
  • SEC Chair, Gary Gensler, stated that easy, online methods are very important in this digital age, and this amendment accomplishes that for investors and filers.
    • Overall, this will benefit the SEC, investors, and filers as it makes the submission and disclosure more transparent, efficient, and operationally resilient.
  • The ability to navigate more effectively and efficiently is now possible for the Commission by expanding to electronic submission.

When will the new Rules and Form Amendments take place?

  • 60 days after publication in the Federal Register is when the new rules and form amendments will be effective.
  • Amendments to Form PF is the one exception to the amendments where it will be effective on January 3rd, 2023.

Important Changes Pertaining to Form 13F

  • Instructions for Confidential Treatment Requests
    • 13(f) Confidential Treatment Request will be required to be filed electronically
      • Electronic filings will be made through EDGAR as a separate, non-public filing.
      • A confidential Form 13F report that is limited to the 13(f) Securities holdings for which the manager is requesting confidential treatment must be included
    • Updated references to new paragraph (i) of rule 24b-2 will change the instruction for Confidential Treatment Requests
  • Summary Page
    • All the same information currently required will be amended to require a manager seeking confidential treatment to specify if confidential treatment is being requested for some or all of the manager’s holdings for the quarter-end period.
  • Special Instructions
    • If confidential treatment is being requested for some or all of the manager’s holdings for the quarter-end period, then  it will be required for managers to identify that on the Summary Page for the new Special Instruction 6(d).
  • Each Form 13F filer will be required to provide an SEC file number and CRD number, if any.
  • Managers would be allowed to disclose, for each security reported on Form 13F, the security’s FIGI in addition to its CUSIP number.
  • Format of Form 13F submissions will now be XML-based structured data language in 2013.
    • Rounding conventions of Form 13F will be requiring all dollar values listed on Form 13F to be rounded to the nearest dollar, rather than to the nearest one thousand dollars as it currently required.
  • 80 character limit imposed on the information filers and the 132 character limit on the information table have been removed.
  • Form 13F’s instructions were simplified to streamline certain sanctions and remove duplicative definitions.

Vigilant’s Final Conclusion

The SEC has made a big stride here in eliminating the paper filings and requiring them to be filed electronically. The SEC Chair stated, this allows for easy, online access for both the Commission and investors. Making the submission and disclosure more transparent, efficient, and operationally resilient was a clear focus by the SEC,

As we noted above, there were quite a number of Amendments to Form 13F that are important to review.

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