Your firm has grown — congratulations. But with that growth comes a new compliance obligation that many emerging advisors aren’t fully prepared for: Form 13F. If your firm manages $100 million or more in Section 13(f) securities, federal law requires you to file quarterly disclosures with the SEC. The challenge for newly required filers isn’t understanding what the form is — it’s figuring out exactly when you need to start, and how to build the infrastructure to file correctly going forward.
How the $100 Million Threshold Works
The filing requirement is triggered by the value of Section 13(f) securities over which you exercise investment discretion, assessed on one specific date: the last trading day of any calendar year. If your firm’s discretionary 13F securities exceed $100 million at year-end, the obligation applies for the entire following calendar year.
Only Section 13(f) securities count toward the threshold — cash, fixed income not on the 13F list, open-end mutual funds, and most foreign equities are excluded. If you cross $100M at year-end, you must begin filing for the first calendar quarter of the following year, with your first deadline typically May 15.
Example: Your firm ends December 31, 2025 with $112 million in discretionary 13(f) securities. You are required to file 13Fs for all four quarters of 2026, starting with your Q1 2026 filing due by May 15, 2026 — regardless of what happens to your AUM during 2026.
What You Need to Set Up Before Your First Filing
Many first-time filers are surprised by the infrastructure required before a 13F can even be submitted. None of this can be assembled at the last minute.
Step 1 — Register for an EDGAR CIK Number. Every filer needs a Central Index Key (CIK) number issued by the SEC. If your firm doesn’t already have one from other EDGAR filings (such as Form ADV), you’ll need to apply in advance.
Step 2 — Obtain EDGAR Access Codes. EDGAR submission requires CIK-specific access codes — your CIK, CCC (CIK Confirmation Code), and password — which must be requested and stored securely.
Step 3 — Map Your Data Sources. Identify which custodians and portfolio management systems hold the data you’ll need, and what export formats are available.
Step 4 — Understand Your Discretion Arrangements. Review your investment management agreements to understand which accounts are fully discretionary, non-discretionary, or shared. This directly affects what must be reported and how.
Step 5 — Plan for XML Preparation. Form 13F must be submitted in SEC-specified XML format. Unless your portfolio management system generates compliant 13F XML directly, you’ll need a purpose-built tool or a professional service provider.
Common Questions from First-Time Filers
Do I have to file even if I cross $100M mid-year? The threshold is assessed at year-end only. If you end the year above $100M, you file for all four quarters of the subsequent year.
Does each portfolio manager have to file separately? No. The obligation falls at the firm level — your firm files one consolidated 13F covering all discretionary positions across all accounts it manages.
What if my AUM drops below $100M? If your AUM falls below $100M at the subsequent December 31 assessment, you may be able to cease filing — but consult legal counsel before stopping your quarterly submissions, as specific procedures apply.
First-time filers are not given a grace period by the SEC. The firms that struggle most with their initial 13F filings are those that treat it as a last-minute task. Start building your workflow now. Contact File|13F — we specialize in helping newly required advisors get their first 13F right.