Registered Investment Advisers ("RIAs") with investment discretion of over $100 million or more of equity securities that trade on an exchange (Section 13(f) securities) must report those holdings quarterly by filing a Form 13F. The Official List of Section 13(f) Securities shows the securities that firms must report on Form 13F. The list is published quarterly. It is available for free by going to https://www.sec.gov/divisions/investment/13flists.htm.
Bates will prepare and submit the Client’s Form 13F including:
Identification of qualified securities
Multiple manager reporting
Preparation of XML Information Table
Submission of XML Table on EDGAR
This service assists the RIA with identifying, uploading, and submitting reporting data. It does not include evaluating an RIA’s holdings.
Form 13H:
Rule 13h-1 defines a Large Trader as a person whose transactions in NMS securities equal or exceed 2 million shares or $20 million during any calendar day, or 20 million shares or $200 million during any calendar month.
The Securities and Exchange Commission adopted Rule 13h-1 to assist the Commission in both identifying and obtaining information on market participants that conduct a substantial amount of trading activity, as measured by volume or market value, in national market system (“NMS”) securities The Large Trader reporting requirements are designed to provide the SEC with data to facilitate the SEC’s ability to assess the impact of Large Trader activity on the securities markets, to reconstruct trading activity following periods of unusual market volatility, and to analyze significant market events for regulatory purposes.
Bates will prepare and submit the Client’s Form 13H initially, and annually, or when the RIA is no longer a “large trader” Bates will file “inactive” status for the RIA.
Form U4:
Representatives of investment advisers must be registered with the appropriate jurisdictions and/or self-regulatory organizations (SROs). The Form U4 (Uniform Application for Securities Industry Registration or Transfer) is used to establish that registration. FINRA, other self-regulatory organizations (SROs) and jurisdictions use the Form U4 to elicit employment history, disciplinary and other information about individuals to register them.
Bates will prepare a draft of Form U4 based on information provided by the RIA/IAR and submit the registration.
Registered individuals are under a continuing obligation to update changes to information required by Form U4 within a specified amount of time by filing an appropriate amendment, as prescribed in the FINRA By-Laws. Bates can assist with the application of those requirements and submit the updated filing(s).
Form U5:
Form U5 is the Uniform Termination Notice for Securities Industry Registration. Investment advisers must use this form to terminate the registration of an individual in the appropriate jurisdictions and/or self- regulatory organizations ("SROs"). A Form U5 must be submitted within 30 days of the individual’s employment end date and generally must be filed electronically. Firms are also required to provide the individual with a copy of their Form U5 within 30 days.
Bates can assist to draft and file the Form U5, as needed for individual registration termination.
