On April 19, the Society joined with the NYSE Group and NIRI to submit a rulemaking petition to the U.S. Securities and Exchange Commission that asks the SEC to update the Form 13F ownership disclosure rules for investment managers.
The petition asks the SEC to reduce the outdated 45-day quarterly filing period, which has been in place since 1979, to five business days to improve the timeliness of 13F data for the benefit of public companies, investors, and other market participants. A five business day deadline would be consistent with the new filing period for Schedule 13D filings that the SEC adopted in October 2023 after a multi-year advocacy effort by the Society and NIRI.
The Society, NYSE, and NIRI previously submitted a rulemaking petition on 13F in 2013, which the SEC has failed to act on. Since then, there has been growing support for modernizing the Form 13F disclosure rules and improving the utility of these disclosures. In 2020, retail shareholders, institutional investors, research firms, issuers, and industry groups submitted hundreds of comment letters that conclusively documented the value of 13F transparency; many of those letters called for accelerating the 13F filing period. The Society and the other organizations encourage the SEC to respond to this broad base of support and move forward with a modernization initiative within the scope of its authority under Section 13(f) of the Exchange Act.
The Society asks members and their companies to consider filing letters in support of 13F modernization. Those letters should be sent via email to "rule-comments@sec.gov" and include File No. 4-825 in the subject line.