Key Takeaways

The SEC Form 13F is a quarterly reporting form required to be filed by all institutional investment managers with at least $100 million in assets under management.

Congress intended to provide transparency on the holdings of the institutional investors via these filings.

Smaller investors frequently use Form 13F as investment guidance, but there are problems with the completeness and timeliness of the data.

Understanding the SEC Form 13F

The Securities and Exchange Commission (SEC)Form 13F is the quarterly reporting form required to be filed by all institutional investment managers with at least $100 million in assets under management.

Congress passed Section 13(f) of the Securities Exchange Act in 1975 to increase public access to information regarding the securities holdings held by institutional investors. Congress believed that this institutional disclosure program would increase transparency and thus lift investor confidence in the integrity of the United States securities markets.

The Form 13F must include the following information:

· the issuer name of all Section 13(f) securities (which should be listed in alphabetical order);

· a description of the class of security listed (e.g., common stock, put/call option, class A shares, convertible debenture);

· the number of shares owned; and

· the fair market value of the securities listed, as of the end of the calendar quarter.

The Form 13F filing is due within 45 days after the end of each quarter of the calendar year. The files can be found on the SEC website

Who must file Form 13F?

Institutional investment managers that use the United States mail (or other means or instrumentality of interstate commerce) when doing their business and that exercise investment discretion over $100 million in Section 13(f) securities must file Form 13F.

An institutional investment manager refers to an entity that either invests in, or buys and sells, securities for its own account. For example, banks, insurance companies, and brokers/dealers. So are corporations and pension funds that manage their own investment portfolios.

An institutional investment manager is also a natural person or an entity that exercises investment discretion over the account of any other natural person or entity. 

A trustee is an institutional investment manager, but a natural person who exercises investment discretion over his or her own account is not an institutional investment manager.

The meaning of Form 13F

The Form 13F filings provide investors with a look at the holdings of Wall Street's top stock pickers, and many smaller investors have sought to use the filings as a guide for their investment strategies. Their rationale is that the nation's largest institutional investors are not only presumably the smartest, but they also have the power to move markets.

However, institutional investment managers are only required to report long positions, apart from their put and call options, American Depositary Receipts (ADRs), and convertible notes. It means that Form 13F doesn't include short positions. Selective reporting can give an incomplete and even misleading picture, because some funds generate most of their returns from their short-selling, only using long positions as hedges. 

Furthermore, the holding data from Form 13F are all historical data. The institutional investment managers may have already changed their positions when the 13F report is published.