This blog was updated on Jan. 4, 2023.
It is critical for 13F filers to be prepared for these new technical requirements, including the cover and information table changes.
On Jan. 3, 2023, the SEC updated the EDGAR system to implement changes related to Form 13F, which is filed by Institutional Investment Managers. On June 23, 2022, the SEC adopted a new final rule to mandate the electronic filing of confidential treatment requests on Form 13F and implement content changes to 13F submissions.
Timing: These changes impact period ending Dec. 31, 2022 filings due by Feb. 14, 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 thenearest 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
- List of Other Managers Reporting for this Manager:
- 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):
Should you have questions about the new 13F submission requirements for Institutional Investment Managers or simply want to speak with a Toppan Merrill expert about getting started with the SaaS platform for 13F compliance, SEC Connect, connect with us via firstname.lastname@example.org or by phone at 800.688.4400.
Jennifer Froberg, Senior Product Specialist at Toppan Merrill
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 and where the agency is headed.
Toppan Merrill’s deep SEC subject matter knowledge provides companies with an array of pragmatic tools to navigate the frequently changing SEC requirements. Jennifer is immersed in how regulatory changes will impact the filers, investors and the market. She has a particular focus on structured data and ESG initiatives.