Separately managed accounts can make Form 13F preparation look more complicated than it is. An adviser may have hundreds of client accounts, several custodians, different portfolio managers, and client-specific voting arrangements. But Form 13F generally is not prepared as a separate schedule for every client.
The central task is to identify the Section 13(f) securities over which the reporting manager exercises investment discretion, then combine or separate those positions according to the Form’s reporting rules.
In many ordinary cases, holdings from separately managed accounts are aggregated by issuer and security class. Account names and client identities do not appear as ordinary columns in the public Information Table. Separate rows are needed only when a reporting characteristic—such as security class, investment-discretion category, Other Included Manager combination, or put/call designation—requires different treatment.
This article explains a practical workflow. It is general educational information, not legal or compliance advice. Contract terms, actual decision-making authority, affiliate relationships, wrap-program arrangements, and confidential-treatment questions may require review by securities counsel or an experienced Form 13F professional.
Start With the Manager, Not the Account Type
Calling an account an “SMA,” “wrap account,” “model portfolio,” or “non-discretionary account” does not by itself determine its Form 13F treatment.
The SEC staff’s Form 13F FAQ says a manager exercises investment discretion if the manager:
- has the power to determine which securities are bought or sold for accounts under management; or
- makes decisions about which securities are bought or sold, even when someone else is formally responsible for the investment decisions.
A manager also is deemed to exercise discretion over accounts for which a person or entity under its control exercises discretion.
The practical question is therefore: What authority does the reporting manager actually exercise over the securities in each account?
Review the advisory agreement, program agreement, subadvisory arrangement, client restrictions, and actual trading process. If the manager only provides a model and another party independently decides whether and how to implement it, the answer may be fact-specific. Do not classify an account solely from a label in a portfolio-management system.
Do SMAs Get Reported Separately on Form 13F?
Usually, no.
SEC FAQ 38 says an advisory firm with sole investment discretion may aggregate all of its holdings in each issuer. The firm does not break out an issuer merely because the positions are held in accounts managed by different individuals within the firm.
For Form 13F preparation, this means separately managed accounts ordinarily feed into one consolidated manager-level Information Table. You generally do not create:
- one Form 13F for each client;
- one row for each client account;
- one filing for each custodian; or
- one row for each internal portfolio manager.
Aggregation is limited to the same issuer and the same class of security, and only positions with compatible reporting treatment belong on the same line.
A Practical SMA Reporting Workflow
Step 1: Build the Complete Account Population
Create an internal account inventory for the reporting manager. Include all relevant separately managed accounts across custodians and portfolio systems.
For each account, record enough internal information to determine:
- whether the manager exercised investment discretion during the relevant analysis;
- the legal entity that exercised that discretion;
- whether discretion was sole or shared;
- whether another independently required manager is involved;
- who held voting authority at quarter-end; and
- where the quarter-end position data will come from.
The internal account identifier is useful for reconciliation, but it is not normally a field in the public Form 13F Information Table.
Step 2: Use Quarter-End Positions and the Applicable SEC List
Collect positions as of the calendar quarter-end and use trade-date reporting, consistent with the SEC staff FAQ.
Match each security against the SEC’s Official List of Section 13(f) Securities for that quarter. A security should not be included merely because it is an equity or because it appeared on a prior quarter’s list.
Preserve at least:
- issuer and class;
- CUSIP;
- optional FIGI, if used;
- shares or principal amount;
- quarter-end fair market value;
- put or call designation, where applicable;
- investment-discretion treatment;
- any applicable Other Included Manager; and
- voting-authority allocation.
Step 3: Normalize Before Aggregating
Custodians and portfolio systems can describe the same security differently. Normalize holdings using the applicable SEC-listed CUSIP and class—not issuer-name similarity alone.
Before adding positions together, confirm that they represent the same:
- issuer;
- security class;
- CUSIP;
- share or principal-amount treatment;
- put/call status;
- investment-discretion category; and
- applicable Other Included Manager combination.
Keep an account-level audit trail behind the aggregation so the reported total can be traced back to its source accounts without exposing client identities in the public table.
Step 4: Aggregate Compatible SMA Positions
Suppose an adviser has sole investment discretion over the same common stock in 40 separately managed accounts. If the positions otherwise have the same Form 13F treatment, combine their shares and market values into one Information Table line.
Do not split that position just because:
- the accounts belong to different clients;
- different employees service the accounts;
- the accounts are held at different custodians; or
- the accounts follow different investment strategies.
Those facts may matter operationally, but they do not automatically create separate Form 13F lines.
Step 5: Split Positions When Reporting Treatment Differs
A single issuer may require multiple rows. Split positions when required by differences such as:
- different security classes;
- stock versus a put, call, or convertible security;
- SOLE versus DFND versus OTR investment discretion;
- different combinations of Other Included Managers in Column 7; or
- another Form instruction requiring segregation.
Client accounts with different voting authority do not necessarily require different rows. Column 8 can allocate the shares on a line among Sole, Shared, and None, provided the rest of the line’s reporting treatment is consistent.
For a fuller explanation of Columns 6–8, see How to Complete the Investment Discretion Section of Form 13F.
Step 6: Reconcile the Filing Back to the SMA Data
Before creating the XML, reconcile:
- every included account to the account inventory;
- every reportable security to the applicable quarter’s Official List;
- aggregated shares and market value to the source positions;
- every split line to a documented reporting reason;
- Column 8 Sole + Shared + None to the shares reported on each ordinary share line;
- every Column 7 number to the Summary Page’s List of Other Included Managers; and
- the Information Table totals to the Summary Page totals.
A technically valid XML file can still contain substantively incorrect aggregation, omissions, or duplicates. EDGAR acceptance does not replace this reconciliation.
SMA Example: Same Security, Different Clients
Assume an adviser has sole investment discretion over common stock of the same issuer in three SMAs:
- Account A: 10,000 shares
- Account B: 15,000 shares
- Account C: 5,000 shares
All three positions have the same CUSIP and class, and no different manager-sharing treatment applies.
The Information Table would ordinarily report one line for 30,000 shares, not three account-level lines.
If the adviser has sole voting authority over 20,000 shares and no voting authority over 10,000 shares, Column 8 would show:
- Sole: 20,000
- Shared: 0
- None: 10,000
The voting allocation totals 30,000 shares. The public line does not identify which client owns which shares.
SMA Example: Different Investment Discretion
Assume the same adviser holds the same common stock in two groups of accounts:
- 25,000 shares over which the adviser exercises sole investment discretion; and
- 8,000 shares over which discretion is shared in a manner classified as shared-other.
Those positions should not be combined into one 33,000-share line. The Form directs filers to segregate holdings by the nature of investment discretion.
The filing would use separate lines for the SOLE and OTR holdings, with Column 7 completed only if the shared position is reported on behalf of an applicable Other Included Manager.
SMA Example: Multiple Custodians
Assume the adviser manages the same stock in accounts at two custodians:
- Custodian 1 reports 12,000 shares; and
- Custodian 2 reports 18,000 shares.
If both files cover the same manager, quarter, accounts, security class, and reporting treatment—and neither dataset duplicates positions already supplied by the other—the positions ordinarily combine into one 30,000-share line.
The control issue is not the number of custodians. It is whether the source files are complete, non-overlapping, and reconciled.
What About Wrap Programs and Model Portfolios?
These arrangements deserve careful review because the sponsor, model provider, overlay manager, subadviser, and account adviser may perform different functions.
Questions to resolve include:
- Who decides which securities are bought or sold?
- Does another party have independent authority to reject or alter model trades?
- Does the reporting manager control another entity that exercises discretion?
- Is discretion shared with another manager that has its own Form 13F filing obligation?
- Who holds authority over non-routine proxy matters?
- Which manager will report any overlapping holdings under the anti-duplication rules?
Do not assume that transmitting a model always creates investment discretion, or that the program sponsor always has it. Apply the SEC definition to the actual arrangement and escalate unclear cases.
Are SMA Client Names Disclosed?
The standard Form 13F Information Table reports security-level holdings and manager-level information; it does not contain ordinary fields for SMA client names or account numbers.
That does not make confidential-treatment analysis unnecessary. Form 13F’s instructions address information that would identify securities held by the account of a natural person, estate, or certain trusts, and the SEC has a specific confidential-treatment process. A manager should not simply omit otherwise reportable SMA positions or assume that aggregation automatically resolves every privacy issue.
If a filing could identify a protected account or if confidential treatment may be appropriate, obtain qualified advice and follow the SEC’s current confidential-treatment procedures.
Common SMA Reporting Mistakes
Filing by account or custodian
Form 13F is generally a manager-level report. Account and custodian files are inputs to the consolidated filing, not separate filing units.
Double-counting an account
The same positions may appear in a custodian export, a portfolio-management-system export, and an overlay-manager file. Define one authoritative source or apply documented deduplication controls.
Treating every account restriction as no discretion
A restriction may limit authority without eliminating the manager’s power to choose other securities. The contract and actual decision-making process must be evaluated.
Aggregating incompatible rows
Do not combine positions with different classes, discretion categories, put/call treatment, or Other Included Manager combinations merely because the CUSIP or issuer looks similar.
Inferring voting authority from trading discretion
Investment discretion and voting authority are separate. Review proxy authority and allocate Column 8 independently.
Using a current account total without a quarter-end tie-out
Form 13F reports quarter-end holdings. Maintain a dated source package and reconcile later adjustments, unsettled trades, and duplicate feeds before filing.
An SMA Preparation Checklist
Before finalizing the filing, confirm that you have:
- identified the reporting manager and all accounts within scope;
- evaluated discretion from the agreements and actual operating arrangement;
- collected complete quarter-end positions across every custodian and system;
- removed duplicate feeds without removing legitimate duplicate holdings;
- matched securities to the correct quarter’s SEC Official List;
- aggregated only the same issuer and class with compatible reporting treatment;
- split positions when investment discretion or manager-sharing combinations differ;
- determined voting authority separately;
- excluded client names and account numbers from the public Information Table;
- evaluated any potential confidential-treatment issue separately;
- reconciled shares, values, line count, and manager references; and
- reviewed the final accepted filing on SEC.gov after submission.
The Bottom Line
Separately managed accounts generally roll up into the reporting manager’s consolidated Form 13F. The filing usually reports aggregated security positions—not an account-by-account client schedule.
The safest workflow is to preserve account-level detail internally, determine discretion and voting authority carefully, aggregate only compatible positions, document every split, and reconcile the final Information Table back to the underlying SMA records.
File13F assists institutional investment managers with position-file intake, data preparation, validation, EDGAR submission support, and filing confirmation. Contact File13F if your SMA data must be consolidated across custodians or reviewed for filing preparation.
Sources
Sources accessed September 28, 2026. SEC materials are the primary authority.
- U.S. Securities and Exchange Commission, Form 13F and Instructions, especially General Instructions 1–2 and Special Instructions 6–11.
- SEC Division of Investment Management, Frequently Asked Questions About Form 13F, displayed update March 6, 2026, especially FAQs 3, 6, 8b, 38, and 45–50a.
- 17 C.F.R. § 240.13f-1.
- SEC, Official List of Section 13(f) Securities.
The SEC’s Form 13F FAQs state that they reflect staff views and are not a rule, regulation, or statement of the Commission. This article is for general informational purposes only. It is not legal, investment, or compliance advice, and it has not been reviewed or approved by the SEC.