When should you file a Form 13F?
The first filing is due 45 days after the fourth quarter has ended of the year the $100 million filing threshold has been met. In other words, the first filing is typically due by February 14 of the following year (i.e., 45 days after December 31). Each additional filing is due 45 days after the end of each quarter (March 31, June 30, and September 30) for the remainder of the year.
It’s important to note that the SEC requires a Form 13F filing even if the manager’s AUM drops below the threshold during the applicable year. This means that so long as, at any point during the year, your firm exceeded $100 million in discretionary Section 13(f) securities, then filing is required.
When should you update Form 13F?
As long as you exceed the $100 million filing threshold in a given year (and meet other requirements established in Section 13(f) and Rule 13f-1), your firm will be required to continue filing quarterly Form 13Fs throughout the following year (i.e., within 45 days of quarter-end).
