Form 13F Filing Requirements: Who Must File and When

Form 13F filing requirements come down to one test: did your firm's investment discretion cover $100 million or more in Section 13(f) securities on the last trading day of any month this year. If the answer is yes, even for one month, you file for the rest of this year and for all four quarters of the next one. This guide covers who counts as a manager, how the monthly test works, the 45 day deadline, what has to go in the filing, and what the SEC has actually done to managers who skip it.

Who has to file Form 13F

Section 13(f) of the Securities Exchange Act of 1934 requires any institutional investment manager that exercises investment discretion over accounts holding $100 million or more in "Section 13(f) securities" to file. That covers more than hedge funds:

• Registered investment advisers
• Banks and trust companies
• Insurance companies
• Pension and endowment funds
• Broker-dealers
• Corporations and individuals who manage their own or client accounts with that much discretion

Being registered as an investment adviser with the SEC has nothing to do with whether Form 13F applies. The trigger is dollar amount of discretion, not registration status. A foreign manager is covered too if it uses US interstate commerce in its business (a US office, US mail, US wires) and crosses the threshold, regardless of where the fund itself is organized. Foreign private issuers face a related but separate set of EDGAR rules on the company side, which is worth knowing if you work across both filer types.

Section 13(f) securities are, broadly, equity securities that trade on a US national exchange: common stock, many ETFs, certain convertible bonds, and equity options. The SEC publishes an official list each quarter; a security not on that list does not count toward the threshold or appear in the filing, even if the manager holds it.

The $100 million threshold and the monthly test

The $100 million figure has not changed since Congress set it in 1975, and it is not indexed to inflation. In 2020 the SEC proposed raising it to $3.5 billion, which one estimate said would have removed about 89 percent of then-current filers from the requirement. As of this writing that proposal has not been adopted, so the original $100 million test still governs.

Rule 13f-1 sets the test as a month end snapshot, not a quarter end one. A manager checks its aggregate discretion on the last trading day of every month. If it crosses $100 million in Section 13(f) securities on even one of those days during a calendar year, it must file a Form 13F for the quarter in which that happened and for every remaining quarter of that year, plus all four quarters of the following year, no matter what its holdings do afterward. A manager cannot drop below the threshold mid-year and skip a quarter.

When Form 13F is due

Form 13F must be filed within 45 days after the end of each calendar quarter.

That gap is also why the data is never current: a position reported on May 15 reflects the manager's holdings as of March 31, up to six weeks earlier. How 13F filing deadlines work covers the weekend and holiday adjustments and how to track a specific manager's filing history against them.

What goes into the filing

Form 13F has three parts: a cover page naming the manager and the report type, a summary page, and an information table in XML format listing every qualifying position. Each row in the table carries the issuer name and class of security, the nine character CUSIP, share count or principal amount, market value at quarter end, whether the position is a put or call, and how voting authority over the shares is split between sole, shared and none. A manager with no reportable holdings for a quarter still has to file, using a Form 13F "notice" or "combination report" instead of a holdings report; the Form 13F-NT notice reports dataset covers that filer group specifically.

If a manager discovers an error in a Form 13F it already filed, it must promptly file an amendment correcting it. A manager can also apply to the SEC's Division of Investment Management for confidential treatment of specific holdings, which delays their public disclosure; omitted positions are published later once the confidential treatment period ends or is denied.

What happens when managers do not file

Form 13F is not optional paperwork that the SEC quietly lets slide. On September 17, 2024, the SEC announced settled charges against 11 institutional investment managers for failing to file Form 13F, two of whom had also missed Form 13H (the separate large trader registration form). Nine of the eleven paid civil penalties totaling more than $3.4 million; the other two avoided a fine because they self-reported the lapse and cooperated with the investigation before the SEC came looking. In most of the cases, the firms had missed filings for an extended stretch and only caught up once the gap was flagged. A week later, the SEC announced a related sweep covering Section 13(f) and Section 16 ownership filings against more than 20 additional entities and individuals.

The pattern across these cases is consistent: late or missing Form 13F filings get found, and self-reporting before an SEC inquiry is the difference between a penalty and none.

Working with 13F data as a developer

If you need to check a manager's filing history or pull its reported holdings instead of reading filings one at a time on EDGAR, SecFeed exposes Form 13F as structured data. The cover page and summary fields come from /v1/form-13f, filtered by CIK and a date range:

curl "https://secfeedapi.com/v1/form-13f?cik=1067983&startDate=2026-01-01" \
  -H "Authorization: Bearer YOUR_API_KEY"

To read the actual positions rather than just the cover page, query the holdings endpoint by CIK or CUSIP:

from secfeed import Client

sf = Client("YOUR_API_KEY")
rows = sf.holdings_13f(cik="1067983", period="06-30-2026")
print(len(rows), "positions reported")
for r in sorted(rows, key=lambda r: r["value"], reverse=True)[:5]:
    print(r["issuer"], r["cusip"], r["value"])

Both endpoints return every field from the original XML information table, so you can build the same cover-page-plus-positions view the SEC form itself has, without parsing XML by hand. What a 13F filing actually shows walks through reading the holdings once you have them, and 13F filings and hedge funds covers the specific limits of using this data to follow fund activity.

Frequently asked questions

Who is required to file a Form 13F?

Any institutional investment manager, including investment advisers, banks, insurance companies, pension funds and broker-dealers, that exercised investment discretion over $100 million or more in Section 13(f) securities on the last trading day of any month during a calendar year.

What is the Form 13F filing deadline?

45 days after the end of each calendar quarter: May 15, August 14, November 14 and February 14, adjusted for weekends and federal holidays.

Does a manager have to keep filing if its holdings drop below $100 million?

Yes. Once a manager crosses the threshold on any month end in a calendar year, it must file for the remainder of that year and for all four quarters of the following year, regardless of what its holdings do in between.

What securities count toward the $100 million threshold?

Only "Section 13(f) securities," a list the SEC publishes each quarter that covers mainly US exchange-listed equities, many ETFs, certain convertible securities and listed equity options. Cash, most bonds and non-listed holdings do not count.

What happens if a manager does not file Form 13F?

The SEC can and does bring enforcement actions. In a September 2024 sweep, nine of eleven managers charged with missed or late Form 13F filings paid a combined $3.4 million in civil penalties; two that self-reported before the SEC's inquiry paid nothing.