Cleary Gottlieb Discusses SEC Proposal to Significantly Change Reporting by Institutional Investors

On July 10, 2020, the Securities and Exchange Commission (the “SEC”) proposed changes that would substantially reduce the number of investors required to file quarterly reports showing their holdings of U.S.-listed equities on Form 13F.[1]  The SEC’s proposal would increase the 13F reporting threshold 35 fold — from $100 million to $3.5 billion — and eliminate the ability to exclude de minimis positions from reporting on Form 13F.[2]  According to the SEC, almost 90% of the investment managers who file a Form 13F today would no longer be required to do so.  However, the SEC’s data … Read more