Challenges Arise with New Form 13F Filing Format

August 9, 2013Articles

Investment managers may be well served to file their upcoming Form 13F reports (due next Wednesday, August 14th) early this quarter.  That is because a new EDGAR filing format went into effect on May 20, 2013, pursuant to which all Form 13F filing must now be made in XML format rather than text-based ASCII format.

All Form 13F filers must now submit their Form 13F using the online form that is available on the EDGAR Filing Website and must construct their Information Table according to the SEC’s new EDGAR XML Technical Specification.  (In connection with this new required filing format, the SEC has issued EDGAR Form 13F XML Technical Specification (Version 1), which can be accessed HERE.)  In order to implement this change, the SEC, in EDGAR Release 13.1, converted Form 13F to an online form. As a result, Form 13F may now only be filed using the new online version of the form available on the EDGAR Filing Website or constructed by Form 13F filers according to the new "EDGAR Form 13F XML Technical Specification" document.

Investment managers should be aware that this new application was not made available for viewing or testing prior to deployment and that, in formulating this new format, the SEC has made the explicit assumption that each Form 13F filer is familiar with the basics of the XML language, Namespaces, and the XML Schema Definition language.  This may result in some managers being hard pressed to file their reports in the new format on the final filing day unless they are fluent in XML language and have pre-tested the EDGAR filing website with respect to their document format.

Having completed numerous Form 13F filings using the new application, we encourage investment managers to file early to avoid last-minute complications.  Should questions arise, we are experienced with the format and have developed strategies for identifying and dealing with some of the potential filing issues.