As we move into 2025, it is crucial for investment adviser firms to stay on top of their regulatory obligations, particularly the requirement to file Form 13F. This filing is mandated by the U.S. Securities and Exchange Commission (SEC) for investment adviser firms which exercise investment discretion over $100 million or more in Section 13(f) securities as of the last trading day of any month during the past calendar year.
Determining Whether Required to File
In order to determine whether your investment adviser firm had discretion over $100 million or more of 13(f) securities on the last trading day of any month during the past calendar year, here’s a link to the current list of 13(f) securities at the website of the SEC. Form 13F must be filed within 45 days of the end of the calendar year when the threshold was reached, and three subsequent reports are required to be filed within 45 days of the end of the first three calendar quarters of the year.
Updated Filing Deadlines
The SEC has updated the filing deadlines for Form 13F for the calendar year 2025. Here are the key dates to remember:
Q4 2024: February 14, 2025
Q1 2025: May 15, 2025
Q2 2025: August 14, 2025
Q3 2025: November 14, 2025
Q4 2025: February 14, 2026
Importance of Timely Filing
Failure to file Form 13F on time can result in significant penalties. The SEC has been vigilant in enforcing these requirements, as evidenced by recent fines imposed on firms for non-compliance. It is essential to ensure that your filings are accurate and submitted by the deadlines to avoid any regulatory issues.
Available To Assist
If your investment adviser firm is an existing client of RIA Compliance Consultants, Inc. and needs assistance with preparing the Form 13F, please contact our Consulting Team for guidance. If your investment adviser firm does not currently work with us, please call our Business Development Team at 877-345-4034 for an introductory call to learn more about services.
Related Resources
SEC Fines Investment Adviser for Failure to File Form 13F
FAQs: Form 13F, Form SH, Schedule 13D & Schedule 13G
SEC Proposed Changes to Form 13F for Institutional Investment Managers (8/3/2020)
SEC’s Deadlines for Filing Form 13F in 2015 (1/4/2015)
Deadline Approaching for Filing the Form 13F with the SEC (1/12/2015)
SEC Settles a Form 13F Filing Violation for a $100,000 Penalty (8/16/2007)
Disclosure
This regulatory alert is a brief summary which is general in nature and offered only for educational purposes. It should not be considered as a comprehensive review or analysis of this obligation. There are certain requirements and exceptions outlined in the rule which are not covered in this regulatory alert. This communication is not intended to constitute compliance consulting advice or apply to any particular investment adviser firm’s specific situation without further analysis. This regulatory alert is not a safe harbor. The reader should study the actual guidance, rule or enforcement action in detail and consult with his or her compliance professionals. This information in this regulatory alert may become out of date.
RIA Compliance Consultants, Inc. is not a law firm and does not provide legal services. This communication is not legal advice. An investment adviser firm which has failed to file Form 13F in accordance with the Securities and Exchange Act of 1934 should immediately consult with qualified legal counsel about self-disclosing such violations to the SEC.
