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07.15.2020
On Friday, July 10, 2020, the U.S. Securities and Exchange Commission (SEC) released proposed modifications of the filing requirements for Form 13F, the quarterly report of holdings of public securities by institutional investors. The most important proposal in the SEC release is to raise the Form 13F reporting threshold from $100 million to $3.5 billion. The release proposes no change in the 45-day reporting deadline following each quarter. The release is available here.
 
This proposal, if incorporated in final rulemaking, will relieve many investment managers, hedge funds and institutional investors from filing the 13F to the extent their aggregate holdings of public securities will be below the new threshold. However, the proposed new threshold would deprive the investment market of data currently included in 13F reports. This was noted by an opposing statement of one SEC commissioner, who said the change would decrease transparency. 
 
There is likely to be opposition expressed during the 60-day comment period, and if the proposal is adopted it may face challenges in federal court, where SEC rulemaking has a mixed track record.
 
Please contact Ed Klees, Brian Farmer or Jim Van Horn with any questions or comments.

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Kristen M. Chatterton
804.771.5637
kchatterton@hirschlerlaw.com

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