News & Analysis as of

Reporting Requirements Form 13F

Sullivan & Worcester

Deadline for Form 13F Filers for New Reporting Requirements on Executive Compensation Votes Rapidly Approaching

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The Securities and Exchange Commission adopted rule and form amendments that will require institutional investment managers who file Form 13F to use Form N-PX to report how they voted proxies on executive compensation (or...more

Goodwin

New Proxy Voting Reporting Requirements For Investment Managers For 2023-24 Annual Meeting Season

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On November 2, 2022, the U.S. Securities and Exchange Commission (SEC) announced the adoption of amendments to Form N-PX and related rules to extend public company stockholder vote disclosure filing requirements beyond...more

Cooley LLP

New SEC Requirements for Form 13F Filers Effective July 1, 2024

Cooley LLP on

In late 2022, the Securities and Exchange Commission (SEC) adopted rule changes that will require institutional investment managers who file Form 13F to annually file a Form N-PX disclosing the manner in which they have voted...more

Morgan Lewis

New SEC Rule Requires 13F Filers to Track and Report on Proxy Voting

Morgan Lewis on

Institutional investment managers that file on Form 13F must make public filings on Form N-PX to report their “say-on-pay” proxy voting. Although the compliance date for this new filing requirement is not until August 2024,...more

Proskauer Rose LLP

SEC Proposes Monthly Short Sale Reporting Requirements: Aggregated Information to be Public; New Order Marking Requirements...

Proskauer Rose LLP on

The SEC recently proposed to require investment managers to report short sale information on a monthly basis if such activity exceeds certain thresholds, and to require broker dealers to begin to mark “buy to cover” trades...more

Kilpatrick

Adjusting for Inflation The SEC Proposes Raising the Form 13F Reporting Threshold from 100

Kilpatrick on

On July 10th, the SEC proposed amendments to Exchange Act Rule 13f-1 that would raise the Form 13F reporting threshold from $100 million to $3.5 billion. If effected, this would be the first change to the reporting threshold...more

Skadden, Arps, Slate, Meagher & Flom LLP

SEC Proposes To Raise Form 13F Reporting Threshold From $100 Million to $3.5 Billion

On July 10, 2020, the Securities and Exchange Commission (SEC) voted 3-1 to approve proposed rules that, among other things, would raise the Form 13F reporting threshold for institutional investment managers (managers) from...more

Lowenstein Sandler LLP

SEC Proposes To Amend Form 13F Reporting Thresholds For Institutional Investment Managers

Lowenstein Sandler LLP on

On July 10, 2020, the Securities and Exchange Commission (SEC) proposed to raise the Form 13F reporting threshold for institutional investment managers from $100 million to $3.5 billion (the Proposal). Currently, investment...more

Goodwin

Financial Services Weekly Roundup: Gone Phishing – The SEC’s OCIE Addresses Ransomware Attacks

Goodwin on

In This Issue. The Securities and Exchange Commission (SEC) adopted amendments to its exemptive applications procedures under the Investment Company Act of 1940, as amended (the 1940 Act) and proposed to amend Form 13F to...more

Kramer Levin Naftalis & Frankel LLP

SEC Proposes Amendments to Update Form 13F

The Securities and Exchange Commission (SEC) has recently proposed to amend the reporting threshold and make certain other changes to Form 13F. It should be noted that this is the first time the reporting threshold would be...more

BCLP

SEC proposes $3.4 billion increase to current $100 million reporting threshold for Form 13F

BCLP on

On Friday, July 10, the SEC proposed amendments to Form 13F to substantially increase the reporting threshold to $3.5 billion from the current level of $100 million and make certain other changes. This would be the first...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Private Funds - February 2020

Dechert LLP on

The U.S. federal securities laws, the Commodity Exchange Act and regulations thereunder, and certain other applicable federal laws, rules and regulations, as well as rules of U.S. self-regulatory organizations (such as the...more

Pillsbury Winthrop Shaw Pittman LLP

Registered Firms: Annual Compliance Obligations—What You Need To Know

This alert contains a summary of the primary annual and periodic compliance-related obligations that may apply to investment advisers registered with the Securities and Exchange Commission (the “SEC”) or with a particular...more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

Dechert LLP on

The U.S. federal securities laws and the rules of U.S. self regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

Dechert LLP on

The U.S. federal securities laws and the rules of U.S. self-regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

Dechert LLP

Reminder: Certain U.S. Reporting and Compliance Obligations for Investment Advisers and Funds

Dechert LLP on

The U.S. federal securities laws and the rules of U.S. self-regulatory organizations (such as the Financial Industry Regulatory Authority) impose certain reporting and compliance obligations on investment advisers and funds....more

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