Regulatory Reporting

Regulatory Reporting

Regulatory status current as of June 2026 — verify effective dates, dollar thresholds, and pending rulemakings against current SEC/FINRA/FinCEN sources before advising.

Core Concepts

Form ADV Amendments

Registered investment advisers must keep Form ADV current through two amendment mechanisms:

Annual updating amendment — Must be filed within 90 days of the adviser's fiscal year end (Rule 204-1 under the Investment Advisers Act of 1940). The annual amendment requires the adviser to review and update all items on Form ADV Parts 1, 2A, and 2B. The adviser must also deliver or offer to deliver the updated brochure (Part 2A) to existing clients within 120 days of fiscal year end, along with a summary of material changes.

Other-than-annual amendments (interim/prompt amendments) — Certain items on Form ADV must be amended promptly when information becomes inaccurate. "Promptly" is generally interpreted as within 30 days of the event, though some changes require faster action. Items requiring prompt amendment include:

• Changes in the adviser's organizational structure, control persons, or ownership (Part 1, Items 1, 2, 3, 7, 10, 11)
• Changes in disciplinary history (Part 1, Item 11, DRPs)
• Changes in the adviser's financial condition that would require disclosure under Part 2A Item 18
• Changes to the brochure (Part 2A) that are material and that clients or prospective clients should know about — including changes to types of advisory services, fee schedules, methods of analysis, risk factors, material conflicts, disciplinary events, or financial condition

Items that may wait for the annual amendment — Statistical information (AUM, number of clients), non-material updates to biographical information, and administrative details that do not affect client decision-making.

Filing via IARD — All Form ADV amendments are filed electronically through the Investment Adviser Registration Depository (IARD) system. Filing fees apply. State notice filings are typically triggered automatically upon SEC filing for advisers relying on SEC registration.

State notice filings — SEC-registered advisers operating in multiple states must make notice filings with each state in which they have a place of business or meet the de minimis threshold. IARD facilitates most state notice filings alongside the SEC filing.

Form ADV-W (Withdrawal) — An adviser withdrawing from SEC registration files Form ADV-W via IARD. Partial withdrawal (from specific states) or full withdrawal from SEC registration. A withdrawal filing becomes effective 60 days after filing unless the SEC institutes proceedings. Firms must maintain books and records for the applicable retention periods after withdrawal.

Form PF (Private Fund Reporting)

SEC Form PF, required under Section 204(b) of the Advisers Act and Rule 204(b)-1, applies to SEC-registered investment advisers that manage one or more private funds.

Filing thresholds and frequency:

• Large private fund advisers to hedge funds — advisers with at least $1.5 billion in hedge fund AUM must file quarterly within 60 days of quarter end. They report on each qualifying hedge fund individually.
• Large private fund advisers to liquidity funds — advisers with at least $1 billion in combined money market fund and liquidity fund AUM must file quarterly within 15 days of quarter end.
• Large private fund advisers to private equity funds — advisers with at least $2 billion in private equity fund AUM must file annually but report more detailed information on each qualifying PE fund.
• Smaller private fund advisers — all other SEC-registered advisers with at least $150 million in private fund AUM file annually within 120 days of fiscal year end. They report aggregate information across all advised private funds.

Content of Form PF filings: AUM and NAV for each reported fund; borrowings and leverage (gross and net); investor concentration (largest investors as a percentage of NAV); asset class exposure and geographic breakdown; counterparty credit exposure (top counterparties); trading and clearing practices (exchange-traded vs OTC); liquidity of portfolio positions; side pocket and gate usage; performance data; investment strategy classification; use of high-frequency trading strategies.

2023 Amendments — Current Reporting (effective 2024): The SEC adopted amendments to Form PF requiring current reporting of certain triggering events:

• Large hedge fund advisers must report within 72 hours of: extraordinary investment losses (20% or more of a reporting fund's NAV over a rolling 10-business-day period), significant margin and default events (failure to meet a margin call that exceeds the reporting fund's NAV by 5% or more), counterparty defaults, material changes in prime broker relationships, changes in unencumbered cash falling below a reporting fund's requirement, and operations events (significant disruption to key operations).
• All Form PF filers for private equity must report within 60 days of: GP-led secondary transactions, adviser-led fund restructurings, removal of a fund's GP, election to terminate a fund's investment period, and election to terminate a fund.

Filing is through the Private Fund Reporting Depository (PFRD), an electronic filing system operated by FINRA on the IARD infrastructure — Form PF is not filed on EDGAR. A filing fee applies to each initial and update filing.

13F Filings (Institutional Holdings)

SEC Rule 13f-1 under Section 13(f) of the Securities Exchange Act of 1934 requires institutional investment managers exercising investment discretion over $100 million or more in 13(f) securities to file Form 13F quarterly.

Who must file: Any "institutional investment manager" — a broad category that includes investment advisers, banks, insurance companies, broker-dealers, pension funds, and corporations — that exercises investment discretion over the threshold amount. The threshold is measured as of the last trading day of any month in the calendar year. Once crossed, the manager must file for every quarter of that calendar year and the following calendar year.

What to report: Long positions in 13(f) securities as of the last day of the calendar quarter. 13(f) securities include: exchange-listed equities and equity-linked securities (common stock, preferred stock, warrants, convertible securities), shares of closed-end funds, certain exchange-traded options (puts and calls), and shares of ETFs. The official list of 13(f) securities is published quarterly by the SEC.

Required data elements: CUSIP number, issuer name, class title (e.g., "COM" for common stock), market value (rounded to the nearest thousand dollars), number of shares or principal amount, investment discretion type (sole, shared, or none), voting authority (sole, shared, or none), and the number of shares for each voting authority type.

Filing deadline: Within 45 days of calendar quarter end (filed on SEC EDGAR).

Confidential treatment requests: Managers may request confidential treatment under Rule 24b-2 for positions where public disclosure would reveal a trading strategy still being implemented (e.g., ongoing accumulation or disposition). The SEC grants confidential treatment on a case-by-case basis and requires a showing that disclosure would likely cause competitive harm. Historically, the SEC has narrowed the grounds for confidential treatment.

Common errors and consequences: Late filings result in public notice and may trigger SEC enforcement. Reporting errors in CUSIPs, share counts, or market values can mislead market participants. Firms must verify 13F data against custodian records and ensure consistent treatment of jointly managed accounts. The SEC has brought enforcement actions for material misstatements on Form 13F.

13H Filings (Large Trader Reporting)

SEC Rule 13h-1 under Section 13(h) of the Exchange Act requires "large traders" to identify themselves to the SEC and receive a Large Trader Identification Number (LTID).

Large trader thresholds: A person (including a firm) is a "large trader" if their transactions in NMS securities equal or exceed:

• 2 million shares or $20 million in fair market value during any single calendar day, or
• 20 million shares or $200 million in fair market value during any calendar month.

Transactions across all accounts over which the person exercises investment discretion are aggregated. The thresholds apply to both purchases and sales.

Form 13H filing requirements:

• Initial filing — must be filed promptly after first meeting the threshold. Filed electronically on SEC EDGAR.
• Annual filing — within 45 days after the end of each full calendar year following initial filing.
• Amended filings — filed promptly upon the occurrence of a material change to previously reported information (e.g., change in organizational structure, new broker-dealer relationships, change in control).
• Inactive status — a large trader that has not met the threshold during the previous full calendar year may file for inactive status. Must reactivate if the threshold is subsequently met.

LTID assignment and use: Upon filing, the SEC assigns an LTID. The large trader must provide the LTID to each broker-dealer through which it trades. The LTID is attached to the large trader's accounts at each broker-dealer.

Broker-dealer obligations: Broker-dealers carrying accounts for large traders must: (a) maintain records of transactions effected through large trader accounts, (b) report large trader transaction data to the SEC upon request (historically via Electronic Blue Sheets, now increasingly through CAT), and (c) monitor for customers who may meet the large trader definition but have not self-identified.

FOCUS Reports

The Financial and Operational Combined Uniform Single (FOCUS) report is the primary financial reporting form for broker-dealers, required under SEC Rule 17a-5 and filed through FINRA's systems.

Filing frequency and form versions:

• Part II — filed quarterly by introducing broker-dealers (firms that do not carry customer accounts or clear transactions). Due within 17 business days of quarter end.
• Part IIA — filed monthly by carrying/clearing broker-dealers (firms that hold customer funds or securities, clear transactions, or carry customer accounts). Due within 17 business days of month end.
• Part IIC — filed by OTC derivatives dealers.

Content of FOCUS reports:

• Statement of financial condition (balance sheet) — assets, liabilities, ownership equity
• Net capital computation (SEC Rule 15c3-1) — the firm's calculation of net capital, showing liquid assets minus liabilities and haircuts. The net capital rule requires broker-dealers to maintain a minimum level of liquid assets to protect customer funds and securities.
• Aggregate indebtedness computation — ratio of aggregate indebtedness to net capital (must not exceed 15:1 for firms using the basic method)
• Customer reserve computation (SEC Rule 15c3-3) — the computation determining whether the firm must deposit funds into a special reserve bank account for the exclusive benefit of customers
• Income statement and revenue detail
• Operational data — possession or control of customer fully paid and excess margin securities

Filing and regulatory oversight: FOCUS reports are filed with FINRA as the firm's designated examining authority (DEA). FINRA reviews filings for accuracy, timeliness, and compliance with net capital and customer protection rules. FOCUS data is shared with the SEC. Late filing, inaccurate filings, or filings showing net capital deficiencies trigger heightened regulatory scrutiny.

Consequences of late or deficient filings: FINRA may impose fines, censure, or suspend a firm for persistent late filings. A FOCUS report showing a net capital deficiency triggers immediate obligations under SEC Rule 17a-11 (discussed in the worked examples below).

Blue Sheets / EBS (Electronic Blue Sheets)

SEC Rule 17a-25 requires broker-dealers to submit, upon SEC request, standardized electronic trading records for specified securities and time periods.

When requested: Blue sheet requests typically arise during SEC investigations into potential insider trading, market manipulation, or other trading violations. The SEC's Division of Enforcement issues blue sheet requests identifying the securities, time period, and type of trading data required.

Data elements: Customer identity (name, address, SSN/TIN), account number, transaction date and time, security identifier (CUSIP/symbol), buy/sell/short sale indicator, quantity, price, executing broker, clearing broker, and the capacity in which the firm acted (principal or agent).

Timeliness: Broker-dealers must respond within the timeframe specified in the request, typically 10 business days. Firms should have systems capable of extracting and formatting blue sheet data promptly.

Relationship to CAT: The Consolidated Audit Trail (CAT) supplies much of the same information for routine regulatory surveillance of NMS equities and listed options. However, as of June 2026 no retirement timeline for the Electronic Blue Sheet system has been announced: data-attribute gaps between EBS and CAT remain, CAT does not cover fixed income, and the SEC continues to issue blue sheet requests in enforcement investigations (including for periods predating CAT). Plan for both systems to coexist, and verify current status before decommissioning any EBS capability.

Enforcement for non-compliance: Failure to respond accurately or timely to blue sheet requests can result in SEC enforcement action. The SEC has brought cases against firms for submitting inaccurate blue sheet data, including incorrect customer identification or missing transactions.

CAT (Consolidated Audit Trail)

SEC Rule 613 mandated the creation of the Consolidated Audit Trail, the most comprehensive order tracking system in U.S. securities markets. The CAT Plan was adopted in 2016, and reporting obligations have been phased in for equities and options.

Who must report: All broker-dealers that are members of a national securities exchange or FINRA ("Industry Members") and all national securities exchanges ("Plan Participants") must report to CAT. This includes introducing brokers, clearing firms, market makers, ATSs, and exchange members.

What is reported: CAT captures every reportable event in the lifecycle of an order for NMS equities and listed options:

• Order origination — receipt of a new order from a customer or another broker-dealer, including order terms (side, quantity, price, time-in-force, order type, special handling instructions)
• Order routing — transmission of an order to another broker-dealer, exchange, or ATS
• Order modification — changes to order terms (price, quantity, time-in-force)
• Order cancellation — cancellation of a pending order
• Order execution — full or partial fill, including execution price and quantity
• Allocation — post-trade allocation to sub-accounts (for institutional orders)

Customer and Account Identifying Information (CAIS): Industry Members must submit CAIS data linking each account to its customer(s). CAIS includes: customer name, address, date of birth (for individuals), SSN/EIN, and account information. CAIS is submitted through a separate reporting channel and must be kept current.

Clock synchronization requirements: Accurate timestamps are essential for order lifecycle tracking. SEC Rule 613 and the CAT NMS Plan require:

• Exchanges and ATSs — clocks must be synchronized to within 50 milliseconds of the National Institute of Standards and Technology (NIST) atomic clock
• Broker-dealers (Industry Members) — clocks must be synchronized to within 1 second of the NIST atomic clo

…

Source & license

This open-source skill is cataloged on AgentStack and links to its original source — we do not rehost the code.

• Author: JoelLewis
• Source: JoelLewis/finance_skills
• License: MIT

Install and usage instructions live in the source repository linked above.