SEC Proposes To Increase Form 13F Reporting Threshold

Proposed Amendments to Form 13F Would Increase the Reporting Threshold from $100 Million to $3.5 Billion, Among Other Changes

On July 10, 2020, the U.S. Securities and Exchange Commission (SEC) issued a proposed rule (the "Proposal") that would raise the Form 13F reporting threshold for investment managers (including non-U.S. investment managers¹ and investment advisers²) to $3.5 billion in Section 13(f) securities, up from the $100 million threshold that has been in effect since the Form 13F filing obligations were adopted in 1978.³

The SEC estimates that the increased threshold would eliminate Form 13F filing requirements for approximately 90% of managers, while retaining disclosure for over 90% of the dollar value of the holdings data currently reported.⁴ The increased threshold is designed to reflect proportionally the increase in the market value of publicly traded U.S. equities since 1975.