You crossed the threshold. The clock is running.

Day 0    Threshold crossed.
Day 1    Pull EMSX blotter exports from all accounts. Reconcile.
Day 1    Call your compliance person. If you don't have one, see below.
Day 2    Confirm EDGAR access. If none, begin Form ID immediately.
Day 3-7  Compile form content. Org chart. Broker list. Strategy description.
Day 8-9  Review with counsel.
Day 10   File. Do not be on Day 11.

The SEC's interpretation of "promptly" is 10 calendar days. Not business days. Calendar days. If you hit the threshold on a Thursday before a three-day weekend, you have the following Saturday plus seven more days. Plan accordingly.

Hit any one of these four numbers and you're filing. Gross basis. Trade date. You know this.

Pull up BTCA on your terminal and check your 30-day rolling aggregates if you haven't been tracking. If you've been relying on the TCA summary page without the cross-account consolidation, your numbers are wrong. You need the full EMSX blotter with all account tags, not the default single-account view.

Gross. Always gross. No netting. No offsets. No "but it was a hedge."

Buy $12M. Sell $12M. Your aggregate is $24M. You are filing.

"Under no circumstances shall a person subtract, offset, or net purchase and sale transactions, in equity securities or option contracts, and among or within accounts."

"Under no circumstances" is unambiguous even by SEC standards.

Counts: Exchange-listed equities, standardized options, ETFs (including leveraged/inverse).

Does not count: OTC, bonds, futures, forex, mutual funds, crypto.

If you're unsure whether something is an NMS security, check SECF on the terminal for its exchange listing status. If it has a primary exchange designation on a national securities exchange and appears in the CTA or OTC UTP transaction reporting plans, it qualifies. In practice: if it has a normal ticker on NYSE or Nasdaq, it counts.

The SEC changed the equity options valuation methodology in 2015. If your compliance infrastructure still uses the underlying-value method, fix that before you file. Running outdated calculations has downstream consequences for your threshold monitoring and you will not enjoy discovering the discrepancy during an examination.

Equity Options — Share Volume

Contracts × multiplier. Standard.

500 contracts × 100 = 50,000 shares.

Equity Options — Dollar Value

Current method (Exemptive Order 34-76322): Premium-based.

Contracts × multiplier × premium per share.

200 calls, 100 multiplier, $15 premium = $300,000.

Not $20,000,000. Not the underlying value. The premium. This changed in October 2015 and there are still compliance systems in the wild computing it the old way. If yours is one of them, you have a different problem to solve before this one.

Index Options — Dollar Value

Contracts × premium per unit × contract multiplier.

100 puts, $51/unit, 100 multiplier = $510,000.

Index Options — Share Volume

Does not apply. Volume is not calculated for index options.

Exercises and Assignments

Excluded. They do not count toward the identifying activity level. The exclusion is intentional — the SEC designed it to prevent double-counting.

Subsequent trading of the resulting shares counts normally. The exercise event itself does not.

The following do not count toward the identifying activity level. They do still get reported to the SEC once you're in the system and the SEC requests data — the exclusion applies only to the threshold calculation.

1. Settlement bookkeeping entries
2. Securities offerings not through a national exchange
3. Gifts
4. Estate distributions
5. Court-ordered transactions
6. Qualified plan/trust rollovers
7. Employer/employee compensatory transactions
8. Business combinations, issuer buybacks, stock loans, equity repos
9. ETF primary creation/redemption (secondary market trading of ETF shares is NOT excluded)
10. Option exercises and assignments

If you have significant activity in category 8, have your counsel run the numbers both with and without. The boundary between an "issuer buyback" and normal secondary market activity is not always obvious and the SEC has not provided extensive guidance on edge cases.

EDGAR is the SEC's electronic filing system. It was built in the 1990s. It has been updated since then, most significantly in 2025, but the experience still reflects its heritage.

You file Form 13H through EDGAR. There is no alternative. No email. No mail. No phone.

If you do not already have EDGAR access, you need to apply for it via Form ID before you can file anything. The SEC currently averages approximately six business days to process Form ID applications. That's six of your ten days gone before you can even begin.

This is the most common reason first-time filers miss their deadline.

In September 2025, the SEC completed the transition to EDGAR Next. The system now requires:

Login.gov credentials. Every person accessing EDGAR needs a Login.gov individual account with multifactor authentication. This is the federal government's single sign-on system.

Account administrators. Individual filers need at least one. Entities need at least two. Each administrator needs their own Login.gov account.

Notarized Form ID. You complete the form online through the Filer Management dashboard (filermanagement.edgarfiling.sec.gov), print it, get it notarized, scan the notarized version to PDF, and upload it. The online version must match the notarized version exactly.

Annual confirmation. Your EDGAR Next account requires annual confirmation that your administrators and authorized users are still correct. Miss the annual confirmation and you lose filing access.

New certifications. Amended Form ID requires certifications about securities law violations for the filer, each administrator, and the signing individual. These certifications carry federal criminal liability under 18 U.S.C. 1001 and 1030.

The dashboard is available 6 AM to 10 PM Eastern, Monday through Friday, excluding federal holidays. You cannot submit Form ID on a Saturday.

Six items.

Item 1 — Business Type and Strategy Description

Select your business category from a dropdown. If you're reading this site, you likely check "Other" and write "Individual investor" or describe your fund structure.

Then describe your trading strategies. In writing. On a form the SEC keeps. More on this below — it deserves its own section.

Item 2 — Other SEC Filings

Do you file 13F, 13D/G, or Section 16 reports? Check the applicable boxes. If you're running PORT on a $100M+ equity book, you probably already file 13F.

Item 3 — CFTC and Foreign Regulators

CFTC registration status. Primary foreign regulator if applicable.

Item 4 — Organizational Chart

Attach a diagram. You, your parent company (if any), all Securities Affiliates (affiliates that trade NMS securities), and all entities from Item 3.

Even as an individual, if you trade through an LLC or trust, diagram the structure. The SEC wants to see the full picture.

Item 5 — Governance

Entity type, jurisdiction, tax ID.

Item 6 — Broker-Dealer List

Every registered broker-dealer where you or your affiliates have an account for NMS securities trading. Every one. Including brokers where you have an account but didn't trade recently.

For each broker: legal corporate name and designation as prime/executing/clearing.

Legal names, not marketing names:

If you're on the terminal, pull up the broker's DLIS profile or check their CRD number on FINRA BrokerCheck. The legal entity name in BrokerCheck is what goes on the form.

After filing, the SEC assigns your Large Trader Identification Number. This is permanent. It does not expire. It follows you for as long as you're a market participant.

LTID Suffixes

Optional. Up to 3 numeric characters. No letters. No special characters. Used to sub-identify different entities or broker relationships under a single parent LTID.

Unless you operate more than three entities, you do not need suffixes. If you're unsure whether you need them, you don't.

The SEC does not notify your broker-dealers. You do.

For each broker where you have accounts:

1. Contact the compliance department. Not customer service. Not your account rep. Compliance. At most major brokers, there is a specific process or form for LTID submission.
2. Provide your LTID.
3. Specify every account at that broker to which it applies.
4. Request written confirmation that they've recorded it.
5. Log the date, the person you spoke to, and the confirmation.

At Interactive Brokers: There is an LTID field in Account Management under regulatory settings. You can enter it directly. The system will ask for your LTID and the applicable account numbers.

At Schwab/Fidelity/etc.: Call the institutional or compliance line. Retail customer service will not know what you're talking about. This is normal. Ask to be transferred to the compliance or regulatory reporting team.

If you open a new brokerage account after filing: You must provide your LTID to the new broker immediately. You must also file a quarterly amendment to Form 13H because your broker-dealer list changed.

Form 13H-A. Due within 45 days of December 31. Every year. Without exception. Until you formally go inactive or terminate.

The 2025 annual filing was due February 17, 2026. The 2026 annual filing will be due approximately February 14, 2027.

Set a recurring calendar event for January 15 with a reminder to begin preparing. The actual filing takes 20 minutes if nothing changed. The cost of missing it is not proportional to the effort required.

Form 13H-Q. Due promptly after any quarter in which information on your form becomes inaccurate.

Trigger events: New broker account, closed broker account, changed address, changed entity structure, changed organizational chart, changed regulatory status.

If you added a new broker relationship in February and also moved in May, you file a quarterly amendment for Q1 (the new broker) and another for Q2 (the address). Two filings.

If nothing changed, no filing required. Only the annual is mandatory regardless of changes.

Eligibility: Full calendar year below all thresholds. January 1 through December 31. Not 12 rolling months.

Timeline:

2025: Active large trader.
2026: Entire year below thresholds.
Early 2027: Eligible to file Form 13H-I (inactive).

Inactive status suspends your annual and quarterly filing obligations and your LTID disclosure requirements. Your LTID still exists. If you cross the threshold again, you must immediately reactivate and resume everything.

Form 13H-T. For permanent cessation of operations only.

Appropriate: dissolved entity, completed acquisition, estate wind-down.

Not appropriate: "taking a break," "moved to crypto," "pivoting to venture." If your brokerage accounts are still open, use inactive status.

You should have filed three months ago and just realized it. This happens more than the SEC would like to admit.

Remediation protocol:

1. Hire compliance counsel today.
2. With counsel, confirm the triggering date and calculate how late you are.
3. Discuss voluntary self-reporting to the SEC.
4. File Form 13H as soon as physically possible.
5. Distribute LTID to all brokers immediately upon receipt.

On self-reporting: In the SEC's September 2024 enforcement sweep, two firms that self-reported their violations paid zero monetary penalties. Every firm that tried to quietly catch up without disclosing the delinquency was fined. The data is unambiguous. Self-report.

This is where most people make their first mistake. They Google "SEC compliance attorney" and call whoever has the best Google Ads placement. This is like choosing a cardiac surgeon based on their Yelp rating.

What you actually need: A securities attorney or compliance consultant with specific experience in Exchange Act Section 13 filings. Not just "SEC experience" — specifically Section 13. Ideally someone who has filed Form 13H for other clients, not someone who will be learning the form alongside you.

How to find them:

Ask your prime broker's compliance desk for referrals. If they won't give names, ask them who they've worked with on 13h-1 matters. They know.

Alternatively, look at the authorship of law firm client alerts about Rule 13h-1. Firms like Seward & Kissel, WilmerHale, Davis Polk, and Paul Hastings have published detailed guidance. The attorneys who wrote those alerts understand the rule. That's a starting point, not an endorsement.

What to ask in the initial conversation:

1. How many Form 13H filings have you prepared?
2. Have you handled a filing for an individual (not an institution)?
3. Are you familiar with the 2015 Exemptive Order for equity options?
4. Do you handle EDGAR filing directly or do you use a filing agent?
5. What is your turnaround time? (This matters when you have 10 days.)

What not to ask:

"Can you explain what Form 13H is?" If you need to ask this, you haven't read this site thoroughly enough. Go back to the top.

Fee expectations:

For a straightforward individual filing with one or two entities and a handful of broker-dealers: $2,000–$8,000 depending on the firm and market. Big law on the higher end, boutique compliance shops on the lower end. This is not a place to optimize for cost. The Cantor Fitzgerald fine was $1.4 million.

The vibe check:

Your compliance professional should not seem confused by anything you tell them about your trading activity. If you mention that you run a systematic equity market-neutral strategy and they ask what "market-neutral" means, leave. You need someone who speaks your language.

If you tell them your daily gross notional and they reach for a calculator to determine whether you've crossed the threshold, that's fine. If they ask you what "gross notional" means, leave.

You've hired someone. Now you have a meeting. Here's how to make it productive instead of a $500/hour tutorial on your own trading.

Before the meeting:

Export your complete trading history. Not a summary. Not a screenshot of your PnL. The full blotter. Every trade, every account, every day, for at least the past 12 months. CSV format.

If you use Bloomberg's EMSX, export via the Excel API or use BHST for historical fills. If you have multiple execution venues, consolidate everything into a single file first. Your attorney does not want to reconcile three different broker export formats. That's your job.

Prepare a clean list of all accounts with broker legal names, account numbers, and whether each broker is prime/executing/clearing.

Prepare your org chart. If your structure is just "me, personally, at two brokers," the org chart is a single box with your name. That's fine. Draw it anyway.

During the meeting:

Your attorney will review the data, confirm whether and when you crossed the threshold, identify any complications (multiple entities, foreign accounts, spousal accounts), and walk through the form content.

The meeting should take 60–90 minutes for a simple case. If you've done the data preparation properly. If you show up with nothing prepared, it'll take three meetings and you'll miss your deadline.

After the meeting:

You should leave with: a completed or near-completed draft of Form 13H, a filing plan with specific dates, and clarity on who is handling the EDGAR submission (you, your attorney, or a filing agent).

Organized in order of importance.

Non-negotiable:

• Complete trade logs from all accounts (12+ months, CSV, every trade)
• Account list with legal broker-dealer names and account numbers
• Tax IDs (SSN and/or EIN for every entity)
• Organizational chart (even if it's one box)
• Date you believe you first crossed the threshold
• EDGAR CIK number and current passphrase (if you have existing access)

Important:

• Options trade detail with premiums (not just P&L)
• Breakdown of equity vs. options vs. ETF activity
• Any prior SEC filings you've made
• CFTC registration details if applicable
• Draft strategy description (2-3 sentences)

Helpful:

• Screenshot of your BBG PORT summary showing account structure
• EMSX account group configuration showing all linked accounts
• List of any accounts you closed in the past year (triggers quarterly amendment for any quarter where the closure occurred)

Item 1 of Form 13H asks you to describe your trading strategies. In writing. On a government filing.

This creates a tension that every systematic trader understands: you need to be accurate enough to satisfy the SEC, vague enough to protect your edge, and concise enough to fit in a text field on a form that was designed in 2011.

The SEC's own example: "Registered market-maker on [SRO], authorized participant for a number of ETFs based on foreign indices, and proprietary trading desk that trades equities and equity options."

Acceptable descriptions for various strategies:

Notice the pattern: asset class + geography + broad strategy type. No mention of signals, models, holding periods, or anything proprietary.

This is a confidential filing. The public will never see it. But SEC staff will, and you do not want your strategy description to become Exhibit A in a market manipulation investigation because you described your approach in a way that sounded more interesting than it is.

Be boring. Deliberately.

This is tangential to Form 13H but not irrelevant, because your accountant will eventually ask you about your LTID status and your filing obligations, and their response to that information will tell you everything you need to know about whether they're competent to handle your situation.

The test: Tell your accountant you've been assigned an LTID. If they know what that means without Googling it, keep them. If they don't, you need a different accountant.

This is not elitism. This is risk management. Your accountant touches your tax filings, your entity structures, and your capital gains calculations. If they don't understand the Large Trader regime, they don't understand the regulatory environment you operate in, and they will eventually make a mistake that costs more than their fees.

What to look for:

An accountant or CPA firm with a practice area in securities taxation and/or financial services. Not a generalist who "also does trading." Someone whose other clients look like you.

The fee conversation:

If your accountant charges you the same rate as a dentist's personal returns, you have the wrong accountant. Trading generates complex tax situations — wash sales, section 1256 contracts, mark-to-market elections, entity-level allocations. Your accountant should be expensive enough that their other clients are also people who trigger SEC filing obligations.

The annual coordination:

Your accountant needs to know:

• Your LTID status (active, inactive, never filed)
• Any entities through which you trade (for entity-level tax returns)
• Your Form 13H filing dates (the annual filing timing should be coordinated with tax preparation)
• Whether you've made a Section 475(f) mark-to-market election (this is a tax decision, not an SEC decision, but it affects how your trading income is characterized, and competent accountants will ask)

The red flags:

• They've never heard of Rule 13h-1.
• They suggest you "probably don't need to worry about it."
• They ask you to calculate your own wash sale adjustments.
• They use TurboTax.

Third-party firms that handle the EDGAR submission for you.

What they do: Form ID application guidance, CIK setup, Form 13H preparation and formatting, EDGAR submission, deadline tracking, annual and quarterly filings.

What they don't do: Legal advice, threshold determination, strategy description drafting. Those are your attorney's job.

When to use one: If your compliance attorney doesn't handle EDGAR filings directly (many don't — their expertise is the substance of the filing, not the mechanics of EDGAR). Or if you're an individual trader without a compliance team and want to minimize your time spent fighting with government websites.

Cost: A few hundred to a few thousand dollars per filing depending on complexity. Trivial relative to the context.

Once your LTID is on file, your broker records two additional data elements for every transaction in your accounts:

1. Your LTID
2. Time of execution

This data sits in their systems, tagged to you, indefinitely. The SEC can request it at any time. Your broker reports it via Electronic Blue Sheets (EBS) and the Consolidated Audit Trail (CAT).

Your broker does not automatically send this data anywhere. The SEC must request it. But the request-to-delivery turnaround is effectively overnight.

If your broker suspects you've crossed the threshold but you haven't provided an LTID, you become an "Unidentified Large Trader."

Your broker then:

• Assigns you a temporary identification number
• Begins maintaining enhanced records on your trades
• Notifies you of your obligations
• Prepares to report your data to the SEC on request

Your trading may be restricted until you provide your LTID. This is not a threat — it's a compliance requirement for the broker. They face their own fines for not handling this correctly. Cantor Fitzgerald was fined $1.4 million partly for failing to identify over 100 Unidentified Large Traders.

Do not put your broker in this position. It is not a conversation either of you wants to have.

Your trades, once tagged with an LTID, flow into two systems:

Electronic Blue Sheets (EBS): Request-based. The SEC asks, the broker provides. Traditional, established, relatively slow. Think of it as the SEC emailing your broker and asking for a spreadsheet.

Consolidated Audit Trail (CAT): Continuous. Collects daily submissions from all reporting firms. Every order, cancellation, modification, and execution for all exchange-listed equities and options. Timestamps synchronized to the NIST atomic clock within 50 milliseconds. Went live for equities in June 2020, options in July 2020.

If you've used BMKT on the terminal to examine market microstructure data, the CAT is the regulatory equivalent — except it captures participant identity, not just tape data. Every order you place, at every venue, through every broker, tagged with your LTID, time-stamped to 50ms precision, stored in a centralized database accessible to the SEC, FINRA, NYSE, CBOE, and every other SRO.

Both systems operate in parallel. Your LTID appears in both.

Once you're a large trader, the reporting activity level drops to 100 shares.

Meaning: the SEC can request your broker report any transaction of 100 shares or more in your accounts. Per day. Per account.

One hundred shares.

The identifying activity level gets you into the system. The reporting activity level means the system sees everything.

Form 13H is confidential. It is exempt from FOIA. The public cannot access it.

But:

• The SEC uses it internally without restriction
• FINRA, NYSE, CBOE, and other SROs have access through EBS and CAT
• Congress can request it
• Courts can order its disclosure

Your competitors won't see it. Your filing will not appear on EDGAR's public search. But the entire regulatory apparatus sees everything.

The rule prohibits disaggregating accounts to avoid identification.

You cannot distribute $5M of daily volume across four brokers and claim each one is below the threshold. The SEC aggregates across all accounts where you exercise investment discretion. If you've structured accounts to stay below the reporting threshold at each individual broker, the SEC considers that evasion — a separate violation with its own consequences.

Don't.

You aggregate across every account where you make the trading decisions.

No individual broker knows your cross-broker aggregate. This is your problem to monitor.

If you're tracking this manually, stop. Pull your daily fills from each broker's FIX drop copy or export the blotter and consolidate programmatically. If you're running EMSX across multiple accounts, set up the account group aggregation to include all entities. The Compliance tab in PORT will show you total activity by account group, but you need to configure the groups correctly first.

Control is presumed if you directly or indirectly:

• Vote or direct the vote of 25%+ of an entity's voting securities, or
• Sell or direct the sale of 25%+ of voting securities, or
• (Partnership) receive upon dissolution or contributed 25%+ of capital

If you and your spouse each own 50% of a trading LLC, both of you are control persons. The LLC's trading aggregates with each of your individual activity.

You can push the filing obligation up or down within a control structure.

Parent files for subsidiaries. Or each subsidiary files individually. The requirement: every person under common control that exercises investment discretion at a registered broker-dealer is covered by someone's Form 13H filing.

For a solo trader with one LLC: either you file and cover the LLC, or the LLC files and covers you. One filing. Not zero.

If multiple large traders share investment discretion over a single account, each person counts only their own transactions toward their individual threshold.

All transactions in the account get tagged with every applicable LTID.

Rule 13h-1 applies to any person — including foreign entities — who uses U.S. jurisdictional means to trade NMS securities above the thresholds.

Foreign traders must file Form 13H. Recordkeeping and reporting obligations fall on the U.S. registered broker-dealers, not the foreign trader directly.

If you're trading U.S. equities through a foreign intermediary with an omnibus account at a U.S. broker, the broker's obligations relate to the intermediary, not the underlying clients.

You can file Form 13H before crossing any threshold. The SEC allows this explicitly.

Rationale:

• Eliminates the 10-day scramble
• Sets up EDGAR access on your own schedule
• Gets the notary requirement out of the way when it's not urgent
• Demonstrates proactive compliance if the SEC ever looks at you

Once voluntarily registered, all ongoing obligations apply normally.

If you run a strategy where your daily gross volume fluctuates between $15M and $25M, do yourself a favor and just register. The monitoring overhead of checking whether you crossed $20M every day is not a productive use of your time compared to the 20 minutes it takes to file.

You can be a 13H filer without being a 13F filer. Most individual large traders are.

If you manage $100M+ and you're pulling your quarterly 13F from the FSEC function on the terminal, you already know this. If you're only filing 13H, the 13F workflow is irrelevant to you.

Automated strategies hit the share volume threshold before the dollar threshold. Two thousand round-trip trades of 1,000 shares each = 4,000,000 shares on a gross basis. One day.

Build threshold monitoring into your execution system. If your order management isn't tracking aggregate intraday gross volume across all accounts, add it. Run a nightly job that checks rolling daily and monthly aggregates and alerts if you're within 20% of any threshold.

If you use EMSX for execution, the Compliance Pre-Trade Check functionality can be configured to include custom rules. This is not a standard out-of-box feature — talk to your Bloomberg representative about setting it up. Alternatively, if you're running your own OMS, add a check at the pre-trade stage that sums gross activity across all accounts for the current day and rejects orders that would push you over threshold. Or just pre-register voluntarily and skip the monitoring entirely.

2011–2022: Effectively zero enforcement of Form 13H obligations. The SEC was building infrastructure.

July 2023 — Cantor Fitzgerald: $1.4 million fine. Filed an initial Form 13H in 2011, then stopped filing for a decade. Also failed to identify 100+ Unidentified Large Traders among customers.

September 2024 — Section 13 Sweep: 34 entities and individuals. 11 institutional managers charged for 13F failures, 2 also charged for 13H failures. Penalties: $10,000 to $750,000 per respondent. Combined fines for 9 firms: over $3.4 million.

2025–2026: Continued focus. SEC examination priorities explicitly reference reporting obligations including 13H. CAT integration has made non-compliance easier to detect.

Two data points at $0 versus twelve data points with fines. The regression is clear. Self-report through counsel.

Stage 1: Discovery.

You learn the rule exists. This typically occurs when your broker's compliance department sends you a letter, when you read a law firm alert, or when you find this website. The dominant emotion is confusion, followed quickly by irritation that nobody mentioned this earlier.

Stage 2: Denial.

You attempt to prove to yourself that you haven't actually crossed the threshold. You re-examine your trades looking for ways to exclude activity. You consider whether your options should be counted differently. You reread the rule hoping to find an exemption that applies to you specifically. This stage lasts between two hours and two days.

Stage 3: Arithmetic.

You pull your actual data and run the numbers honestly. The result is unambiguous. You have crossed the threshold. You may have crossed it months ago.

Stage 4: Scramble.

You realize the 10-day deadline and begin executing the filing process at high velocity. This is when most people discover the EDGAR/notary bottleneck.

Stage 5: Filing.

The form is submitted. It takes less time than you spent on Stage 2.

Stage 6: Maintenance.

You set up calendar reminders for annual filings and move on with your life. The form takes 20 minutes per year. The emotional weight was entirely front-loaded.

• Store your CIK and CCC in a password manager. Not in a text file on your desktop. Not in your email.
• Your Login.gov credentials are separate from your EDGAR credentials. Both matter. Secure both.
• The annual confirmation requires an account administrator to log in and confirm. Set a calendar reminder. If you miss the confirmation window plus the three-month grace period, you lose access entirely and must resubmit Form ID with notarization.
• If you use a filing agent, they will need delegated access through your EDGAR Next dashboard. Understand what permissions you're granting before you grant them.

If you manage cryptographic keys for your trading infrastructure, apply the same operational security discipline to your EDGAR credentials. They cannot be rotated as easily as API keys and the recovery process involves paper forms and government employees.

They probably won't. But if they do.

The scenario: You receive a call or letter from the SEC's Division of Trading and Markets, or from the Division of Examinations, referencing Rule 13h-1 or your LTID.

Step 1: Do not answer substantive questions on the spot. Be polite. Ask for the name and contact information of the SEC staff member. Tell them your attorney will be in touch.

Step 2: Call your compliance attorney. Immediately. Not tomorrow. Today.

Step 3: Your attorney will handle all communication with the SEC from this point.

What they're likely asking about:

• Why your annual filing is late
• Why your LTID doesn't appear at a broker where they've identified your activity
• Clarification of information on your Form 13H
• Transaction data related to a broader investigation (not about you specifically)

What they're almost certainly NOT doing:

• Calling to compliment your filing timeliness
• Offering compliance advice

Most SEC inquiries related to 13H are routine data requests or examination-related follow-ups. They are not enforcement actions. But every interaction with a federal regulator should go through your attorney. That's what you're paying them for.

Your terminal already has most of the data you need for threshold monitoring and filing preparation.

Daily threshold monitoring:

Set up a MARS report or custom Excel template linked via BDH/BDP that pulls your daily fills across all EMSX-connected accounts. Sum gross shares and gross notional by day. Compare against 2M shares and $20M. If you're within 20% of either threshold, investigate.

If you're not using EMSX and your execution is through a separate OMS or DMA provider, export the fills to a common format and consolidate. The terminal is not the only source of truth but it should be one of them.

Form 13H preparation:

• PORT: Pull your account structure and verify all linked entities
• DLIS: Look up legal names of your broker-dealers
• SECF: Verify NMS status of any securities you're uncertain about
• FA: Pull financial data for entity-level information if needed
• MSG: Contact your Bloomberg rep about compliance monitoring tools if you want to automate threshold alerts

Post-filing monitoring:

• Set up a MARS alert or custom monitor that flags any day where gross activity exceeds 80% of the daily threshold
• If you trade index options, run a separate calculation since volume doesn't apply (dollar value only)
• Review monthly aggregates on the first business day of each month

None of this is specific to Bloomberg — any data infrastructure that captures your fills across all venues and accounts can do this. But if you have a terminal, the tools are already there. Use them.

Maintain a permanent record of:

1. Threshold calculations: Daily and monthly aggregates going back to the date you believe you first approached the threshold. Keep the raw data (fills) and the calculations.
2. Filing history: Copies of every Form 13H filing, the date of submission, and the SEC's acceptance confirmation.
3. LTID distribution records: Date, broker name, contact person, and confirmation for every broker notification.
4. Quarterly amendment triggers: A log of what changed and when, so you can demonstrate that you filed amendments promptly after the relevant quarter.
5. Compliance meeting notes: Keep records of advice received from your compliance professional, including dates and key decisions.

Store this in whatever system you use for other compliance records. If you don't have a compliance record system, create one. A folder in your document management system is fine. A shared drive with your accountant is better.

Retention period: the SEC hasn't specified one for Form 13H records from the large trader's side. The broker-dealer retention requirement under the rule references existing recordkeeping obligations, which typically means at least 6 years under Exchange Act Rule 17a-4. Match that or exceed it.

1. Using the pre-2015 options valuation method. The premium-based method has been available for over a decade.
2. Counting option exercises/assignments toward the threshold. They're excluded.
3. Missing the annual filing. Every year. No exceptions.
4. Not providing LTID to all brokers. Every broker. Even the one you opened six months ago and forgot about.
5. Confusing inactive and terminated status.
6. Not aggregating across all accounts.
7. Using marketing names instead of legal entity names for brokers.
8. Waiting for your broker to notify you that you crossed the threshold.
9. Filing for termination when you meant inactive.
10. Forgetting that leveraged ETFs count by dollar value, which can be multiples of what you'd expect for a given share count.
11. Not monitoring monthly aggregates separately from daily.
12. Opening a new broker account and not filing a quarterly amendment.
13. Letting EDGAR credentials expire and discovering this on Day 8 of your 10-day deadline.
14. Trying to quietly backfill late filings without self-reporting.
15. Describing your trading strategy in too much detail on the form.
16. Ignoring the EDGAR Next annual confirmation requirement.
17. Assuming your accountant understands the Large Trader regime.
18. Not keeping records of when you notified each broker of your LTID.
19. Treating the 10-day deadline as 10 business days. It's calendar days.
20. Thinking this doesn't apply to you because you're "just a retail trader."

• Confirmed threshold crossing date
• Pulled complete trade logs from all brokers
• Calculated aggregate gross volume and value (daily and monthly)
• Engaged compliance counsel
• Confirmed EDGAR access (or begun Form ID application)
• Prepared organizational chart
• Compiled broker-dealer list with legal entity names
• Obtained tax IDs for self and all entities
• Drafted trading strategy description
• Reviewed form content with counsel
• Submitted Form 13H via EDGAR
• Received LTID from SEC

• Notified all broker-dealers of LTID
• Received confirmation from each broker
• Logged notification dates and contacts
• Set calendar reminder for annual filing (January 15)
• Set calendar reminder for quarterly review of form accuracy
• Established daily/monthly threshold monitoring process
• Informed accountant of LTID status
• Stored filing confirmation and credentials securely
• Reviewed EDGAR Next annual confirmation deadline

1. Rule 13h-1 (current text)
2. Adopting Release 34-64976
3. Exemptive Order 34-76322
4. Form 13H and Instructions
5. SEC FAQ — Large Trader Reporting
6. EDGAR Next Information
7. Form ID Application Guide