In addition to the Information table (which is currently generated by FundApps), Institutional Investment Managers must also submit a Cover page and a Summary page (From 13F Q&A No. 31) when disclosing under Section 13F in the US. Both of these documents complement the Information table and provide information (e.g. File Number, CIK) related to the reporting manager and for ‘other included managers’ in the case where the reporting entity shares investment discretion with other managers and is reporting holdings on their behalf.

The cover and summary pages will be generated by the rule Major: US - 13F under one document: MajorUS-13F-HR, both in XML and HTML formats. For an overview of the structure of 13F and how the information is displayed, see this article.

In order to generate these forms, the following portfolio properties have been created. These must be populated for the (reporting) Top entity, and for each portfolio if it is managed by a 13F Institutional Investment Manager other than the Top entity (if any). Full details of these properties can also be viewed within the Properties screen in FundApps.

Description - Name of the 13F Investment Manager.

Where to set - Each Portfolio.

This property is required for the Major: US - 13F - Eligibility rule to run. Please provide InvestmentManager13F at all Portfolios. If you do not provide this property at every portfolio, an unknown will trigger under the 13F Eligibility rule with the reason - OriginalPortfolioInvestmentManager13F.

If this property does not currently relate to your activity and you wish to mitigate this unknown from your environment, then we recommend:

Clients who have more than one investment management entity involved (i.e. shared investment discretion) based on their corporate relationship should use this property to specify the name of the manager for each relevant portfolio. They should set the exact same value/name across all portfolios that share the same 13F investment manager.
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For portfolios where the Top entity in the ‘Management’ aggregation tree is the 13F investment manager, the exact name of the Top Entity should be set for this property on the portfolios which share that manager.

Description - Whether the InvestmentManager13F entity for a portfolio or Top Entity is 13F reportable.

Where to set - Top Entity; all Portfolios.

Set IsInvestmentManager13FReportingEligible as True if the InvestmentManager13F for the Portfolio was determined to be reportable at last year-end and False if the InvestmentManager13F was determined to be not reportable.

It is important to set IsInvestmentManager13FReportingEligible as the same value for each InvestmentManager13F. This means that every Portfolio which shares the same InvestmentManager13F property must have the same value for IsInvestmentManager13FReportingEligible.

If IsInvestmentManager13FReportingEligible is populated differently for Portfolios that have the same InvestmentManager13F, the document will not generate correctly.

If IsInvestmentManager13FReportingEligible is set to True, then the 13-F securities under this InvestmentManager13F will be listed separately on the form.

Description - Affiliation of the 13F investment manager.

Where to set - any entities and Portfolios where the investment manager is not in your corporate group.

This property should only be populated if the reporting entity shares investment discretion with other managers that are not part of their corporate group.

Portfolios that are reported by another manager (i.e. not within the 13F form generated by FundApps) should have this property set to “UnaffiliatedExclude.”

Where portfolios are mapped to InvestmentManager13FAffiliation = “UnaffiliatedExclude” the “List of Other Managers Reporting for this Manager” section in the 13F form will include the managers mapped to the InvestmentManager13F property.

Portfolios mapped to “Affiliated” or “UnaffiliatedInclude” will have those managers included in the 13F form as ‘Other Included Managers’.

For portfolios managed by group entities, this property may be set to “Affiliated”, or will default to Affiliated if left blank. Where the portfolio is reported on behalf of the other manager, it should be set to “UnaffiliatedInclude.”

All assets in portfolios set to UnaffiliatedExclude will be excluded from the information table, and related values on the cover sheet (e.g. Number of Other Included Managers, Form 13F Information Table Entry Total, etc.)

If any portfolios are set to UnaffiliatedExclude, the 13F report will be automatically labelled as a 13F Combination Report. In all other cases, it will continue to be treated as a 13F Holdings Report.

Description - Tracking number beginning with a '028-' prefix that the SEC assigns to each Form 13F filer after their first filing.

Where to set - Top Entity; Portfolios managed by a different 13F Institutional Investment Manager where InvestmentManager13F is set.

Description - The Central Index Key or CIK number is a ten-digit number given to an individual or company by the SEC. The number is used to identify the filings of a company, person, or entity in EDGAR.

Where to set - Top Entity; Portfolios managed by a different 13F Institutional Investment Manager where InvestmentManager13F is set.

Description - This field should be populated for the (reporting) Top entity, and only if it is located in the US or CA. It is used to populate the <stateOrCountry> element of the XML version of the cover page, according to the Form 13F XML Technical Specification.

Where to set - Top Entity (Only if Top Entity is located in the US or CA)

Description - This field should be populated for the reporting person assigned to the Top entity, and only if she is located in the US or CA. It is used to populate the <stateOrCountry> element of the XML version of the cover page, according to the Form 13F XML Technical Specification.

Where to set - Top Entity (Only if Top Entity’s Reporting Person is located in the US or CA)

You can see how these above portfolio properties affect the 13F Cover and Summary pages below:

Q: Do I need to set these properties on my portfolios if I file 13F as “SOLE” - meaning that there is only one 13F investment manager (and that is the Top entity)?

A: No. (If you are certain that you have one 13F investment management entity). See 12(b)(vi) of the 13F instructions for further information.

Q: Why do you run the 13F rule on the Top entity in our Management aggregation structure? I don’t think I should file 13F for the Top entity - it’s technically not an investment management entity.

A: 13F takes into account all entities which might be considered to “control” the investment management entities, and that includes holding companies of investment management subsidiaries. See the regulation itself 13f-1(b), Question 45 and 46 of the official 13F Q&A, and 12(b)(vi) of the 13F instructions. The meaning of “control” may not have the same meaning as applied in other areas of US law.

Q: Why do I have to populate values for properties related to our Investment Management entities on our portfolios?

A: Consider a few reasons:

Q: Why do I need to set these properties on the Top Entity if I’m also setting them on portfolios?

A: FundApps needs these properties since the Top Entity is considered the reporting entity. The other properties listed above under the “Each Portfolio” sections correlate to the investment manager declared in InvestmentManager13F.

Q: What if I have assets within a portfolio that are managed by different Investment Managers (i.e. multi-managed portfolios)?

A: FundApps doesn’t currently support the ability to automate the 13F form for split or multi-managed portfolios.