What does a Form 13F leave out?

Who files a 13F, and what does it cover?

Rule 13f-1 requires an institutional investment manager that exercises investment discretion over accounts holding Section 13(f) securities with an aggregate fair market value of at least $100,000,000 on the last trading day of any month of a calendar year to file a Form 13F. Section 13(f) securities are equity securities of a class described in Section 13(d)(1) of the Act that are admitted to trading on a national securities exchange or quoted on an automated quotation system of a registered securities association. The SEC publishes an official list of them, updated each quarter, and the rule says only securities of a class on that list are reported.

OQRO explains the basics in what a Form 13F shows. This article is about the other side: what the form omits.

What is left out?

One further point: a manager that lends securities still reports them. The SEC answers say securities owned and loaned to a third party are reported by the owner, and the borrower should not report them.

Is every holding publicly shown?

Not always. Section 13(f)(4) allows the SEC to prevent or delay public disclosure of information reported on the form, and the form's instructions set out how a manager can request confidential treatment, including for holdings of a natural person's account. A request must be supported by facts, and the part for which treatment is sought is filed separately. The public filing indicates that confidential information has been omitted.

What time does the snapshot show?

The report covers the calendar year or quarter ended, and Form 13F is due within 45 days after the end of the calendar year and each of the first three calendar quarters of the next year. The filing is a position list as of the last day of the period. A holding bought and sold within the quarter never appears. A position that looks new can have been bought on any day of the quarter. Timing is covered in when 13F filings are due.

Who is a 13F filer, in practice?

The rule applies to institutional investment managers, which the FAQ shows includes foreign managers that use US commerce in their business and have enough US-listed holdings. The rule is not limited to hedge funds: it applies to every institutional investment manager above the threshold. OQRO follows a selected set of managers on its institutions page; the live count is on its coverage page.

What is a sensible reading checklist?

First, check the filing's period and its filing date: the snapshot is the last day of the quarter, and the report can come up to 45 days later. Second, remember that it lists long positions only. Third, compare two quarters' tables for the same manager to see which positions appear, disappear or change in size; the form itself reports no trades, so the difference is a comparison of two snapshots. Fourth, look for amendments, which can restate an earlier report. Fifth, remember that some holdings may be omitted under a confidential treatment request. A reader who follows these five steps will describe the filing accurately, which is all it supports.

What does the form include?

For each holding, the information table gives the issuer's name, the title of the class, the CUSIP number, the market value as prescribed by the form's special instruction on valuation, the number of shares or the principal amount, whether the holding is a put or a call, the type of investment discretion (sole, shared-defined or shared-other), any other managers, and the voting authority. Those are the facts the form supports: what was held, in which class, in what amount and with what discretion, on one date.

What this does not tell you

A 13F does not show whether a manager has hedged a position with a short, an option not on the list, or a holding abroad. A large long position may be offset elsewhere in the portfolio, and the filing gives no view of net exposure. It does not show the price paid, the profit, or the reason for a position. A manager that appears to have bought a stock may have been holding it for years if it was already in earlier filings. For that reason OQRO describes changes between two quarter-end snapshots and does not describe trades.