SEC Proposes Increase for 13F Threshold

The SEC has proposed to amend Form 13F to update the reporting threshold for institutional investment managers from $100 million to $3.5 billion. The threshold has not been adjusted in over 40 years. Section 13(f) of the Exchange Act requires an investment manager to file a report with the SEC if the manager exercises investment discretion with respect to accounts holding certain equity securities having an aggregate fair market value on the last trading day of any month of any calendar year of at least $100 million. If the amendments are approved, that threshold would be raised substantially. The proposal would also require SEC review of the Form 13F reporting threshold every five years and would eliminate the ability of managers to omit certain small positions.