Supporting Statement_Form 13F (2025)

OMB CONTROL NUMBER: 3235-0006
SUPPORTING STATEMENT
For the Paperwork Reduction Act Information Collection Submission for
FORM 13F
A.

JUSTIFICATION
1.

Necessity for the Information Collection

In 1968, Congress directed the Securities and Exchange Commission to make a study of
the purchase, sale, and holding of securities by institutional investors to determine the effect of
those activities upon the maintenance of fair and orderly securities markets, the stability of those
markets, and the interests of issuers of securities and of the public. As a result of that study,
Congress in 1975 adopted Section 13(f) of the Securities Exchange Act of 1934 (the "1934 Act")
as part of the Securities Acts Amendments of 1975. The reporting system required by Section
13(f) of the 1934 Act is intended, among other things, to create in the Commission a central
repository of historical and current data about the investment activities of certain institutional
investment managers, and to improve the body of factual data available in order to facilitate
consideration of the influence and impact of institutional investment managers on the securities
markets as well as the public policy implications of that influence.
Section 13(f) of the 1934 Act empowers the Commission to: (1) adopt rules that create a
reporting and disclosure system to collect specific information; and (2) disseminate such
information to the public. Rule 13f- 1 under the 1934 Act (17 CFR 240.13f-1)requires
institutional investment managers that exercise investment discretion over accounts that have in
the aggregate a fair market value of at least $100,000,000 of certain U.S. exchange-traded equity
securities, as set forth in rule 13f-1(c), to file quarterly reports with the Commission on Form
13F.
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On June 23, 2022, the Commission adopted amendments to Form 13F to require, among
other things, institutional investment managers that make confidential treatment requests for
filings made under Section 13(f) of the 1934 Act to submit them electronically via EDGAR. 1
2.

Purpose and Use of the Information Collection

The purpose of Form 13F is twofold: (1) to provide a reporting and disclosure system to
collect information about certain equity security holdings of institutional investment managers;
and (2) to disseminate such information to the public.
3.

Consideration Given to Information Technology

The Commission's electronic filing system (Electronic Data Gathering, Analysis, and
Retrieval System, or "EDGAR") is designed to automate the filing, processing and dissemination
of disclosure filings. Using the EDGAR system, publicly held companies generally transmit their
filings to the Commission directly over the Internet. See Rulemaking for EDGAR System,
Release No. 33-7855 (April 24, 2000) (part of the modernization of EDGAR). Such automation
has increased the speed, accuracy and availability of information, generating benefits to investors
and financial markets. In addition, Form 13F is filed in an online format that requires, among
other things, that the Form 13F Information Table be submitted in XML (Extensible Markup
Language), which helps filers avoid common mistakes and improves data quality.

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See Electronic Submission of Applications for Orders under the Advisers Act and the Investment Company Act,
Confidential Treatment Requests for Filings on Form 13F, and Form ADV-NR; Amendments to Form 13F, Release
No. IC-34635 (June 23, 2022). The amendments to Form 13F also require managers to provide additional
identifying information and allow managers to disclose, for any security reported on Form 13F, the security’s share
class level Financial Instrument Global Identifier. The rules also make certain technical amendments, including to
modernize the structure of data reporting and amend the instructions on Form 13F for confidential treatment
requests in light of a recent decision of the U.S. Supreme Court.

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4.

Duplication

The Commission periodically evaluates reporting and recordkeeping requirements for
duplication and reevaluates them whenever it proposes a rule or form or a change in a rule or
form. The information required by Form 13F is not generally duplicated elsewhere.
5.

Effect on Small Entities

The requirements of Form 13F are the same for all potential filers. An institutional
investment manager is not subject to Form 13F reporting unless it exercises investment
discretion over, in the aggregate, at least $100,000,000 in certain equity securities.
6.

Consequences of Not Conducting Collection

See Item 1, above. Not collecting the information would: (i) be a failure to comply with
the requirements of Section 13(f) of the Securities Exchange Act of 1934; and (ii) eliminate
disclosure about certain U.S. equity security holdings of institutional investment managers that
currently is available to the Commission and the public.
7.

Inconsistencies with Guidelines in 5 CFR 1320.5(d)(2)

Not applicable.
8.

Consultation Outside the Agency

The Commission requested public comment on the information collection requirements
in Form 13F before it submitted this request for extension and approval to the Office of
Management and Budget. The Commission’s solicitation of public comments included
estimating and requesting public comments on updated burden estimates for all information
collections under this OMB control number. The Commission received no comments in
response to its request.
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9.

Payment or Gift

Not applicable.
10.

Confidentiality

Section 13(f)(4) of the 1934 Act (15 U.S.C. 78m(f)(4)) authorizes the Commission, upon
request, to delay or prevent public disclosure of any information filed under Section 13(f) as it
determines to be necessary or appropriate for public interest reasons or to protect investors.
Section 13(f)(4) also prohibits the Commission from disclosing to the public information
identifying securities held by the account of a natural person or any estate or trust (other than a
business trust or investment company).
11.

Sensitive Questions

No information of a sensitive nature, including social security numbers, will be required
under this collection of information. The information collection collects basic Personally
Identifiable Information (PII) that may include information on an institutional investment
manager’s name, Form 13F file number, business address, and name-title-business phone number
of the person that signs the form on behalf of the reporting manager. However, the agency has
determined that the information collection does not constitute a system of records for purposes of
the Privacy Act. Information is not retrieved by a personal identifier. In accordance with Section
208 of the E-Government Act of 2002, the agency has conducted a Privacy Impact Assessment
(PIA) of the EDGAR system, in connection with this collection of information. The EDGAR
PIA, published on 2/5/2020, is provided as a supplemental document and is also available at
https://www.sec.gov/privacy.

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12.

Burden of Information Collection

In our most recent PRA submission for Form 13F, we estimated a total hour burden of
101,339.29 hours, with an external cost burden of $ 4,846,374. 2 Estimates concerning the
burdens associated with the information collections required by rule 13f-1 and Form 13F are set
forth in the table below. The estimate of average burden hours is made solely for the purposes of
the Paperwork Reduction Act. The estimate is not derived from a comprehensive or even a
representative survey or study of Commission rules. Reporting burdens may differ substantially
across respondents.

2

This estimate is based on the last time the rule’s information collection was submitted for PRA renewal in 2022.

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Table: Form 13F PRA Estimates
Initial
hours

Internal time cost
Annual hours

Wage rate

External
costs1

PRA B UR DEN ESTIMATES
Burdens for 13F-HR Filings
$314
Estimated burden per filing

Number of filings
Annual burden of Form 13F-HR
filings

2 hours

x

(blended rate for
compliance attorney, senior
programmer, and
compliance clerk)2

$628

28,925
filings4

28,925 filings

57,850
hours

$18,164,900

$2213

28,925
filings
$6,392,425

Burdens for 13F-NT Filings

Estimated burden of per filing

Number of filings
Annual burden of Form 13F-NT
filings

2 hours

$247 (blended
rate for senior
programmer
and compliance
clerk)6

x

6,935
filings5

$494

6,935 filings

13,870
hours

$3,425,890

$757

6,935
filings
$520,125

Burdens for Form 13F Amendment Filings
$314

Estimated burden per
amendment

Number of amendments
Annual estimated burden of all
amendments

2 hours

x

(blended rate for
compliance attorney, senior
programmer, and
compliance clerk)2

$628

1,450
amendments8

1,450 amendments

2,900 hours

$910,600

$757

1,450 amendments

$108,750

TOTAL ESTIMATED FORM 13F BURDEN
Currently approved burden
estimates
Revised current burden estimates

101,339.29 hours

$22,092,421.60

74,620 hours

$22,501,390

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$4,846,374
$7,021,300

Notes:
1. The external costs of complying with Form 13F can vary among filers. Some filers use third-party vendors for a range of services in connection with filing reports on
Form 13F, while other filers use vendors for more limited purposes such as providing more user-friendly versions of the list of section 13(f) Securities. For purposes of the
PRA, we estimate that each filer will spend an average of $300 on vendor services each year in connection with the filer’s four quarterly reports on Form 13F-HR (13F
Holdings or Combination Report) or Form 13F-NT (13F Notice), as applicable, in addition to the estimated vendor costs associated with any amendments. In addition,
some filers engage outside legal services in connection with the preparation of requests for confidential treatment or analyses regarding possible requests, or in connection
with the form’s disclosure requirements. For purposes of the PRA, we estimate that each manager filing reports on Form 13F-HR will incur $584 for one hour of outside
legal services each year. The Commission’s estimates of the relevant wage rates for external time costs, such as outside legal services, take into account staff experience, a
variety of sources including general information websites, and adjustments for inflation.
2. This estimated burden is from Securities Industry and Financial Markets Association’s Management & Professional Earnings in the Securities Industry 2013, modified by
Commission staff to account for an 1800-hour work-year and inflation, and multiplied by 5.35 to account for bonuses, firm size, employee benefits and overhead (“SIFMA
Wage Report”). The wage rate reflects current estimates from the SIFMA Wage Report of the blended hourly rate for a compliance attorney ($449), senior programmer
($408), and compliance clerk ($86) (($449+$408+$86)/3=$314.33).
3. This includes an estimated $300 paid to a third-party vendor in connection with the Form 13F-HR filing as well as an estimated $584 for one hour of outside legal
services ($884/4 filings per year=$221 per filing). We estimate that Form 13F-HR filers will require some level of external legal counsel in connection with these
filings.
4. This estimate is based on the number of 13F-HR filings averaged over three years as of December 2024.
5. This estimate is based on the number of Form 13F-NT filings averaged over three years as of December 2024.
6. The wage rate reflects current estimates from the SIFMA Wage Report of the blended hourly rate for a senior programmer ($408) and compliance clerk ($86)
(($408+$86)/2=$247).
7. This includes an estimated $300 paid to a third-party vendor in connection with the Form 13F-NT filing and Form 13F amendments ($300/4 filings per year=$75 per
filing).
8. This estimate is based on the number of Form 13F amendments filed averaged over three years as of December 2024.

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13.

Cost to Respondents

Cost burden is the cost of goods and services purchased to comply with Form 13F,
such as legal services. The cost burden does not include the hour burden discussed in Item 12
above. As outlined in the table above, we estimate the total external cost burden to comply to
be $7,021,300.
14. Cost to the Federal Government
The SEC is in the process of revising its methodologies to estimate annualized costs to the
Federal government for all its relevant collections of information. The SEC anticipates that
future extensions of this collection of information will reflect the revised methodologies.
15. Change in Burden
The estimated burden has changed as follows.
Table: Change in Burden Estimates
Number of Responses
Time Burden (hours)
Previously Current Change Previously Current
approved estimate
approved estimate
Form 32,380
37,310
4,930
101,339.29 74,620
13F

Cost Burden (dollars)
Change Previously Current
Change
approved estimate
-26,719.29 $4,846,374 $7,021,300 $2,174,926

We have revised the estimates to reflect changes in the number of affected entities and in
the external cost associated with the information collection requirements. These changes reflect
revised estimates and burdens attributable to requirements under the rule and form.
16.

Information Collection Planned for Statistical Purposes

Not applicable.
17.

Approval to Omit OMB Expiration Date

Not applicable.
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18.
Exceptions to Certification Statement for Paperwork Reduction Act
Submission
Not applicable.
B.

COLLECTIONS OF INFORMATION EMPLOYING STATISTICAL METHODS
Not applicable.

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