Properties for the 13F Cover and Summary Pages

In addition to the Information table (which is currently generated by Rapptr), Institutional Investment Managers must also submit a Cover page and a Summary page (From 13F Q&A No. 31) when disclosing under Section 13F in the US. Both of these documents complement the Information table and provide information (e.g. File Number, CIK) related to the reporting manager and for ‘other included managers’, in the case where the reporting entity shares investment discretion with other managers and is reporting holdings on their behalf.

The cover and summary pages will be generated by the rule MajorUS-13F under one document: MajorUS-13F-HR, both in XML and HTML formats. For an overview of the structure of 13F and how the information is displayed see this article.

 

Portfolio Properties

In order to generate these forms, the following portfolio properties have been created. These must be populated for the (reporting) Top entity, and for each portfolio if it is managed by a 13F Institutional Investment Manager other than the Top entity (if any). Full details of these properties can also be viewed within the Properties screen in Rapptr.

 

InvestmentManager13F

Description - Name of the 13F Investment Manager.

Where to set - Each Portfolio.

This property is required for the 13F Eligibility rule to run. Please provide InvestmentManager13F at all Portfolios. If you do not provide this property at every portfolio, an unknown will trigger under the 13F Eligibility rule with the reason - OriginalPortfolioInvestmentManager13F.

If this property does not currently relate to your activity and you wish to mitigate this unknown from your environment then we recommend:

  • adding the PortfolioName of the top entity under the InvestmentManager13F column to all your portfolios that sit under an entity to your portfolio file or
  • by adding PortfolioName of the top entity to the InvestmentManager13F property under Disclosure Form Properties>Other Form Properties.


Clients who have more than one investment management entity involved (i.e. shared investment discretion) based on their corporate relationship should use this property to specify the name of the manager for each relevant portfolio. They should set the exact same value/name across all portfolios that share the same 13F investment manager.

For portfolios where the Top entity in the ‘Management’ aggregation tree is the 13F investment manager, the exact name of the Top Entity should be set for this property on the portfolios which share that manager. 

 

Description - Whether the InvestmentManager13F entity for a portfolio of Top Entity is 13F reportable.

Where to set - Top Entity; all Portfolios.

Set Is13FManagerReportingEligible as True if the Top Entity for the Portfolio was determined to be reportable at last year-end, and False if the Top Entity was determined to be not reportable.

It is important to set Is13FManagerReportingEligible as the same value for each InvestmentManager13F. This means that every Portfolio which shares the same InvestmentManager13F property must have the same value for Is13FManagerReportingEligible.

If Is13FManagerReportingEligible is populated differently for Portfolios that have the same InvestmentManager13F, the document will not generate correctly.

InvestmentManager13FAffiliation

Description - Affiliation of the 13F investment manager.

Where to set - any entities and Portfolios where the investment manager is not in your corporate group.

This property should only be populated if the reporting entity shares investment discretion with other managers that are not part of their corporate group.

Portfolios that are reported by another manager (i.e. not within the 13F form generated by Rapptr) should have this property set to “UnaffiliatedExclude.”

Where portfolios are mapped to InvestmentManager13FAffiliation = “UnaffiliatedExclude” the “List of Other Managers Reporting for this Manager” section in the 13F form will include the managers mapped to the InvestmentManager13F property.

Portfolios mapped to “Affiliated” or “UnaffiliatedInclude” will have those managers included in the 13F form as ‘Other Included Managers’.

For portfolios managed by group entities, this property may be set to “Affiliated”, or will default to Affiliated if left blank. Where the portfolio is reported on behalf of the other manager, it should be set to “UnaffiliatedInclude.”

All assets in portfolios set to UnaffiliatedExclude will be excluded from the information table, and related values on the cover sheet (e.g. Number of Other Included Managers, Form 13F Information Table Entry Total, etc.)

If any portfolios are set to UnaffiliatedExclude, the 13F report will be automatically labeled as a 13F Combination Report. In all other cases, it will continue to be treated as a 13F Holdings Report.

Form13FFileNumber

Description - Tracking number beginning with a '028-' prefix that the SEC assigns to each Form 13F filer after their first filing.

Where to set - Top Entity; Portfolios managed by a different 13F Institutional Investment Manager where InvestmentManager13F is set.

Form13FCIK

Description - The Central Index Key or CIK number is ten-digit number given to an individual or company by the SEC. The number is used to identify the filings of a company, person, or entity in EDGAR.

Where to set - Top Entity; Portfolios managed by a different 13F Institutional Investment Manager where InvestmentManager13F is set.

Form13FProvinceState

Description - This field should be populated for the (reporting) Top entity, and only if it is located in US or CA. It is used to populate the <stateOrCountry> element of the  XML version of the cover page, according to the Form 13F XML Technical Specification.

Where to set - Top Entity (Only if Top Entity is located in US or CA)


Form13FReportingPersonProvinceState

Description - This field should be populated for the reporting person assigned to the Top entity, and only if she is located in US or CA. It is used to populate the <stateOrCountry> element of the  XML version of the cover page, according to the Form 13F XML Technical Specification.

Where to set - Top Entity (Only if Top Entity’s Reporting Person is located in US or CA)

 

Portfolio Properties Implemented

You can see how these above portfolio properties affect the 13F Cover and Summary pages below:13F_page_1.JPG13F_page_3.JPG13F_page_2.JPG13F_page_4.JPG13F_page_5.JPG

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FAQ:

 

Q1: Do I need to set these properties on my portfolios, if I file 13F as “SOLE” - meaning that there is only one 13F investment manager (and that is the Top entity)?

A1: No. (If you are certain that you have one 13F investment management entity). See 12(b)(vi) of the 13F instructions for further information.

 

Q2: Why do you run the 13F rule on the Top entity in our Management aggregation structure? I don’t think I should file 13F for the Top entity - it’s technically not an investment management entity.

A2: 13F takes into account all entities which might be considered to “control” the investment management entities, and that includes holding companies of investment management subsidiaries. See the regulation itself 13f-1(b), Question 45 and 46 of the official 13F Q&A, and 12(b)(vi) of the 13F instructions. The meaning of “control” may not have the same meaning as applied in other areas of US law.

 

Q3: Why do I have to populate values for properties related to our Investment Management entities on our portfolios?

A3: Consider a few reasons:

  • The entities that are relevant for 13F are not necessarily all of those in your “Management” aggregation structure (see the definition of InvestmentManager13F in Rapptr’s property screen). Setting the name of the relevant Investment Management entity on the portfolio level accounts for any differences.
  • The hierarchy of the investment managers covering each portfolio may not be the same as that reflected by your “Management” aggregation structure in Rapptr.

 

Q4: Why do I need to set these properties on the Top Entity if I’m setting them on portfolios as well?

A4: Rapptr needs these properties since the Top Entity is considered the reporting entity. The other properties listed above under the “Each Portfolio” sections correlate to the investment manager declared in InvestmentManager13F.

 

Q5: What if I have assets within a portfolio that are managed by different Investment Managers (i.e. multi-managed portfolios)?

A5: Rappr doesn’t currently support the ability to automate the 13F form for split or multi-managed portfolios.

 

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