Overview
As recently announced, 13F is moving from Shareholding Disclosure into our dedicated Regulatory Reporting product suite.
This move brings 13F into a more streamlined reporting workflow, making it easier to manage forms, apply updates and changes, and prepare filings.
It also unlocks a number of key enhancements designed to make the reporting process more efficient and flexible:
In-UI Editing: Directly edit the cover page and information table all within the UI.
Multi-Manager Support: Easily handle multiple managers in column 7 of the information table.
Simplified Admin: Easier management and configuration of form properties.
Built-in Validation: EDGAR validation is baked into the workflow.
Activity Logs: Fields are fully editable, with real-time tracking showing what changed and who made the update.
Side-Bar Navigation: Quickly find a specific section or field via the Table of Contents.
Approval Workflow: Approve fields and sections to track form completeness in real-time.
We are currently in the roll-out phase, and you will be contacted by your relevant CSM once it has been enabled in your environment.
Required Configuration Changes
Before using the new functionality, several configuration changes and form property updates are required. Your CSM will help guide you through these changes.
Updated form properties, which are detailed later in this article.
Slight changes to the aggregation structure may also be required; in this case, guidance will be provided by your CSM.
How the Functionality Works
Instead of navigating to the 13F result at the end of the quarter in Shareholding Disclosure, you can now simply navigate to Regulatory Reporting, create a new filing instance for 13F, and specify the year, quarter, entity, and aggregation structure.
Once created, the report will automatically populate the Filer Information, Cover Page, and Information Table sections by leveraging your form properties and backend rule calculations (similar to the current workflow).
Editing and Approvals
When reviewing the Filer Information and Cover Page sections, changes can be made directly in the Regulatory Reporting UI. Any change made is automatically tracked in the Activity Log for that field.
Once a section is complete, it can be approved. Each approved section is added to the tracker at the top of the page, which displays the percentage of approved fields.
Similar to the above, the Information Table section can also be edited or adjusted directly in the UI if needed. Entire rows can be removed or added, and the columns within each row can be edited. Again, any changes will be tracked, and once approved, the tracker will be updated.
Throughout the UI, you may see red validation errors associated with completed fields. Our team has implemented many of the EDGAR validation requirements in the workflow, and each error should be resolved before submitting to EDGAR. While we cannot account for all requirements, many are supported and serve as a great starting point before filing.
Making Edits in Excel
Each section can be downloaded directly from the UI. Edits can be made in Excel and then reuploaded into the UI for users who need to make multiple adjustments or prefer working in spreadsheets.
Once the review process is complete, generate the form via the Generate submission option under Report Actions. We will generate two XML files for submission to EDGAR. One containing the Filer Information and the Cover Page, and the other containing the Information Table.
Form Properties
InvestmentManagers13F
Numerous clients have requested the ability to populate multiple managers in Column 7 of the Information Table. To support this, we have created a new property called InvestmentManagers13F.
This replaces the former InvestmentManager13f property and can be populated with multiple investment managers for instances where management discretion is shared.
Clients with more than one investment management entity involved (i.e., shared investment discretion) due to their corporate relationship should use this property to select the manager name for each relevant portfolio.
This will be a dropdown property, and each relevant investment manager must be present in the aggregation as an entity. If not, you can work with your CSM to add a new entity to your applicable structure.
This should be populated across each portfolio in your structure.
IsOtherReportingManager13F
Whether the InvestmentManagers13F entity for a portfolio is 13F reportable.
This only needs to be populated at the investment manager entity level, whereas the former property (IsInvestmentManager13FReportingEligible) was required at the portfolio level.
New Entity-Level Properties
The following newer versions of the former Form 13F properties must be populated across the top-level entity and any investment manager entities.
US13FFileNumber
The Form 13F File Number is an SEC tracking number, beginning with the '028-' prefix, that the SEC assigns to each Form 13F filer after their first filing.
If the investment manager or top entity does not have a File Number assigned, leave it blank.
USCRDNumber
The Central Registration Depository number.
Every financial advisor ('registered representative') of a brokerage firm licensed to sell securities has one.
If a manager is filing a Form 13F notice report or Form 13F-HR, the manager must include the CRD number, if available, for any manager included in the report.
USSECFileNumber
The SEC File number.
If a manager is filing a Form 13F notice report or Form 13F-HR, the manager must include, if available, the SEC file number of any manager included in the report.
USSECCIK
The Central Index Key is an SEC tracking number assigned to each filer.
Existing Portfolio-Level Properties
The following properties remain as-is and should continue to be populated at the portfolio level.
VotingAuthority13FUS
Reported as SOLE, SHARED, or NONE based on voting rights for non-routine and routine matters.
SOLE: Voting authority on non-routine matters (e.g., contested election of directors, merger, sale of substantial assets, change in articles of incorporation affecting shareholders, change in fundamental investment policy). If voting authority is shared only in a manner similar to a 'SHARED' (Defined) investment discretion, the voting authority should be reported as 'SOLE', depending on the account holders' voting rights.
SHARED: Voting authority on non-routine matters, and depending on the voting rights of the account holders.
NONE: No voting authority or voting authority ONLY on routine matters (e.g., selection of accountant, the uncontested election of directors, approval of annual report).
Please see SEC Form 13F FAQs, question 50a and SEC 13F General Instructions, section 11.b.viii, for more details on the definition of each value.
InvestmentDiscretionUS
Reported as SOLE, DFND (Defined), or OTR (Other) depending on how the entity manages and controls Section 13(f) securities.
SOLE: Only one entity manages Section 13(f) securities, and the entity does not control (or is not controlled by) another reporting person.
DFND: (Defined) The entity that manages Section 13(f) securities controls (or is controlled by) another reporting person.
OTR: (Other) Investment discretion is shared in a manner that does not fit into the 'SOLE' or 'DEFINED' category.
For the legal definition of each value from the SEC, please see Form 13F FAQs (questions 45 - 47).
Deprecated Properties
The following property will be deprecated and is no longer required.
InvestmentManager13FAffiliation
If you currently populate UnaffiliatedExclude, your CSM will walk you through creating an additional aggregation tree for 13F, removing the portfolios reported by the other manager.