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Are foreign institutional investment managers required to file Form 13F?

April 26, 2017file foreign form institutional Investment managers

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Are foreign institutional investment managers required to file Form 13F?

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Yes, if they: (1) use any means or instrumentality of United States interstate commerce in the course of their business; and (2) exercise investment discretion over $100 million or more in Section 13(f) securities. See Section 13(f)(1) of the Securities Exchange Act and SEC Release No. 34-14852 (June 15, 1978). Question 5 Q: Must an institutional investment manager file Form 13F even if it is not an SEC-registered investment adviser because it does not meet the definition of investment adviser in Section 202(a)(11) of the Investment Advisers Act? A: Yes. If the manager meets the requirements of Section 13(f) of the Securities Exchange Act, it must file Form 13F regardless of whether it is an SEC-registered investment adviser. Banks, bank holding companies, and broker/dealers that exercise investment discretion over $100 million or more in Section 13(f) securities are required to file Form 13F, even though they are excluded from the definition of investment adviser in Section 202(a)(11)