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BLOG Aug 18, 2020

IHS Markit Perspectives Special - Issuer feedback on the SEC’s 13-F threshold proposal

Between July 31 and August 10, 2020, IHS Markit's Perception team undertook a survey of the issuer community to gauge initial market reactions to the SEC's proposal to raise the 13-F reporting threshold to $3.5B from $100M.

For this special IHS Markit Perspectives report, we asked Chief Financial Officers and Investor Relations professionals of U.S. listed companies for their feedback on the proposal and how it may impact them. The survey includes a total of 110 issuers, representing $1.94T in market capitalization (ranging from $35M to $400B) and covering all 10 major industries.

Highlights include:

  • Over 80% of respondents strongly oppose the 13-F proposal and nearly everyone plans to voice their opposition through one or more channels.
  • Issuers anticipate that the proposed change will have largely negative impacts to their investor relations workflow, visibility into shareholder activity, and ability to monitor activist investors.
  • Many respondents believe that the 13-F threshold level does not need to be changed and instead they offer suggestions about how the 13-F process can be altered to increase transparency.

Download report link

View preceding report IHS Markit's SEC's 13-F Proposal: Issuer and Investor Analysis

View Perception's Perspectives Series Part 1, Part 2, Part 3, Part 4, Part 5, Part 6, and Part 7.


S&P Global provides industry-leading data, software and technology platforms and managed services to tackle some of the most difficult challenges in financial markets. We help our customers better understand complicated markets, reduce risk, operate more efficiently and comply with financial regulation.


This article was published by S&P Global Market Intelligence and not by S&P Global Ratings, which is a separately managed division of S&P Global.

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