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On June 23, 2022, the Securities and Exchange Commission (SEC) adopted new electronic filing requirements for 13F Confidential Treatment Requests, applications for orders under the Advisers Act and Investment Company Act, and Form ADV-NR for non-resident advisers. The SEC also approved a handful of changes to the information reported on Form 13F.

Confidential Treatment Requests for Form 13F filings and applications for orders under the Advisers Act and Investment Company Act will be required to be filed electronically on the SEC’s Electronic Data Gathering, Analysis, and Retrieval (EDGAR) system. Form ADV-NR for non-resident general partners and managing agents of investment advisers will be required to be submitted electronically through the Investment Adviser Registration Depository (IARD) system.

The amendments to Form 13F include:

  • Amending the summary page to require a manager seeking confidential treatment to indicate if confidential treatment is being requested for some or all of the manager's holdings for the quarter.
  • Requiring filers to provide additional identifying information such as its Central Registration Depository number (CRD number) and SEC file number, if any.
  • Permitting the use of a Financial Instrument Global Identifier (FIGI) in addition to the CUSIP number.
  • Certain technical amendments to the instructions, such as requiring all dollar values to be rounded to the nearest dollar and removing the requirement that filers omit the “000” when reporting dollar values on Form 13F.

These changes will modernize the filing process and increase the SEC’s efficiency in processing submissions.

The electronic filing requirements will become effective on August 29, 2022. There will be a six-month transition period to allow sufficient time to convert to the new electronic procedures.

The amendments to Form 13F will become effective on January 3, 2023.

Click to view the SEC Final Rule and Fact Sheet on Amendments to Electronic Filing Requirements.

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Heather A. Scott

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