Important Notes Regarding Form 13F Filing Alerts and Reports Provided by Us
The following are important things that advisors trading through our system should keep in mind when reviewing any Form 13 F-related alerts and reports they receive from us:
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We are providing advisors Form 13 F-related alerts for informational purposes only. Advisors should independently review their Form 13F filing obligations. There are numerous aggregation, de minimis, shared investment discretion, and other specific reporting rules that may impact what information must or may not be reported on the form and who must report it. For instance, a manager may omit holdings otherwise reportable if it holds, on the period end date fewer than 10,000 shares (or less than $200,000 principal amount in the case of convertible debt securities) and less than $200,000 aggregate fair market value (including option holdings to purchase only such amounts). The SEC also expects any 13F reports to meet certain file format requirements.
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Form 13 F alerts sent out by us generally take into account only the holdings of the specific advisor identified, in the absence of a request from the advisor to aggregate its holdings with those of another advisor. The advisor or a related person who controls the advisor may be deemed to have investment discretion with respect to other accounts or holdings not accounted for in this notice. For instance, even if a parent company exercises no discretion over accounts managed by its subsidiaries, the parent may nonetheless be deemed to have shared investment discretion.
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Form 13 F alerts sent by us relate only to accounts maintained at us and not any accounts maintained elsewhere. But advisors should take any accounts they maintain elsewhere into consideration when determining whether they must file Form 13F and what information to include in their Form 13F.
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We started monitoring advisors’ Form 13 F filing obligations on [insert date of when this program was launched] and any alerts and reporting provided by us to advisors trading on its platform do not concern advisors’ Form 13F filing obligations arising before that date.
If advisors have any questions regarding any Form 13F alerts or reporting they have received from us, they should contact our Client Services or email us at Form13F@interactivebrokers.com.