Client Reminder: Important Shareholder Disclosure Obligations for Investment Managers and Funds under Section 13 of the US Securities Exchange Act of 1934

January 22, 2008
Investment managers and funds that have discretion over or beneficially own more than certain amounts of US equity securities registered under the US Securities Exchange Act may have to report these holdings to the Securities Exchange Commission (“SEC”). These reporting obligations apply to all investment managers and funds regardless of whether they are registered with the SEC and regardless of where they are organised. The SEC has brought enforcement actions for failure to file the required forms and schedules on a timely basis. This article explains which forms need to be filed, by whom, and the filing schedule and deadlines for each.