Market Data Requirements for U.S. 13f2 Short Reporting

We are offering end-to-end position monitoring and filings with SEC, with full automation and provision of market data. Contact us for further details.

The adoption of Rule 13f-2 introduces significant operational complexity and costs due to its requirements. Managers will have to develop intricate systems to assess their global securities positions relative to the Filing Thresholds. Currently, there are no readily available data sources that link individual securities in the US, or globally, to the Reporting Company Issuer Filing Thresholds. Many institutional investment managers might have to evaluate all positions under the Filing Threshold for Non-Reporting Company Issuers before determining if a security qualifies as an equity security as defined in Section 3(a)(11) of the Exchange Act and Rule 3a11–1, or if it meets one of the higher Reporting Company Issuer Filing Thresholds.

Data points

Following is a non-exhaustive list of data which is required to enable monitoring and reporting:

Which securities are Section 12 securities (generally public offerings)?
Which securities are issued by the companies subject to SEC reporting requirements?
Which companies have been granted the reporting exemptions from SEC?
Which securities are dually listed?
Get data for OTC securities
Shares outstanding (with due care in selecting correct type of shares)
Closing Prices / Last Prices
FX rates
Issuer Name (not the security name) and Issuer LEI
Security CUSIP code
Security FIGI code
Class Title
Potentially Global Settlements calendars

Verify and reconcile

There are multiple verifications and reconciliations required to get the quality of data right. E.g. need to check whether a security is a Section 12 security and whether the issuer of that security is filing 15d filings or not. There are no ready datasets where this is provided in a certified manner. So, there will be a whole bunch of custom monitoring software with manual verifications and reconciliations required to support a lot of this.

Your choice

We will provide clients two choices:

Bring Your Own Data - you can plug in your own data, and we will use that to monitor and report your portfolio
Let DisclosureWise use internally sourced data points, which means the clients will not need to worry about any of the above

How we can help

This is the most complicated monitoring and reporting regime that we have seen and poses challenges across the monitor and report workflow. In our opinion, this is a monitoring challenge, and the actual reporting is a minor part of it. A lot of the market data points required are either not readily available or require extensive system and operational investment.

We will be able to source all market data internally, or allow clients to plug in their own data. We will monitor the portfolio, evaluate all positions as per rules, prepare reports, get user approval, lodge the filings with EDGAR and confirm back to you.

However, our implementation focus is our existing clients who use our service for Global Monitoring and Reporting. If you are interested in onboarding, we strongly suggest that you engage today. We will not be able to onboard clients closer to the deadline due to the complexity of the implementation.

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