Do You Qualify for Form 13F? Understanding the $100 Million Threshold
Wondering if you're required to file Form 13F? If you manage $100 million or more in reportable securities, the answer is likely yes — here's how to know for sure.
What Triggers a 13F Filing Requirement?
You must file Form 13F if:
You are an institutional investment manager, which the SEC defines as any person or entity that invests in, or buys and sells, securities for its own account or for the accounts of others
You exercise investment discretion over $100 million or more in 13F securities as of the end of any month in a calendar year
This includes:
Registered investment advisers (RIAs)
Hedge funds and private fund managers
Bank trust departments
Insurance companies
Family offices
Any other entity or person managing securities portfolios
It doesn’t matter whether you’re SEC-registered — if you meet the discretion and threshold tests, you’re required to begin filing.
Quick Checklist: Do You Qualify for 13F?
You manage investment accounts for clients or your own firm
You exercise investment discretion
You had $100M+ in 13F securities at the end of any month this year
What Counts Toward the $100 Million Threshold?
Not all assets under management (AUM) count — only the portion made up of reportable 13F securities.
These typically include:
U.S.-listed equities (including ETFs and ETNs)
Certain options, convertible notes, and structured products
Some debt instruments — but only if they appear on the SEC’s official 13F list
They do not include:
Mutual fund shares
Most bonds or traditional fixed-income instruments
International equities not listed on U.S. exchanges
You can review the SEC’s Official List of 13F Securities to determine what counts.
When Do You Have to Start Filing?
If your discretionary 13F securities exceed $100 million at any month-end, you must begin filing with the Q4 Form 13F of that same calendar year.
You must continue filing at least through the third quarter of the following year, even if your qualifying assets dip below $100 million during that time.
Example:
If you cross the threshold in August 2025, your first required filing will be for Q4 2025 (due February 14, 2026). You’ll continue filing through Q3 2026. If you remain below $100 million for the entirety of 2026, you can stop filing beginning Q4 2026.
Can ACN Help Determine if I Qualify?
Yes — if you're unsure whether you’ve crossed the $100 million threshold, we’ll run a quick analysis for you.
Send us your holdings list, and we will:
Identify which of your positions are 13F-reportable
Calculate your total discretionary value in 13F securities
Let you know if you’ve passed the $100 million threshold as of any month-end
Provide you with a clear spreadsheet of the results — free of charge
While we don’t offer legal advice or make formal compliance determinations, this analysis helps most managers confidently understand their filing obligations.
For a full overview, see our Form 13F FAQ
Need Help Figuring It Out?
ACN Solutions is the market leader in Form 13F filings — trusted by more investment managers than any other service provider. In fact, over 10% of all Form 13F filers rely on ACN to prepare and submit their reports quickly, accurately, and on time.
We help RIAs, hedge funds, family offices, and other investment managers:
Understand their filing obligations
Identify reportable holdings using the 13F list
Generate and submit SEC-ready filings with confidence
Not sure where you stand? We’ll analyze your holdings, check for qualifying 13F securities, and provide a clear threshold report — free of charge.
Contact us today to get started.
Disclaimer
The information provided in this blog post is for general informational purposes only and does not constitute legal, compliance, or financial advice. ACN Solutions LLC is not a law firm, compliance advisor, or affiliated with the Securities and Exchange Commission (SEC). While we strive to provide accurate and timely guidance based on publicly available SEC resources, we do not speak on behalf of the SEC and are not authorized to interpret its rules or policies. Readers should consult their legal counsel or compliance professionals for specific guidance related to their regulatory obligations.