Do family offices have to file Form 13F?
Yes. A family office that exercises investment discretion over $100 million or more of listed Section 13(f) securities must file Form 13F with the SEC every quarter, within 45 days of quarter end. Being exempt from registering as an investment adviser does not change that.
40
single-family offices whose public 13F filings were read by a person for this cohort, out of 51 filers a screen proposed. Every one of them files because the rule below applies to them.
Why is there no family office exemption from 13F?
Two different laws are often read as one. The family office rule under the Investment Advisers Act lets a single-family office advise its own family without registering as an adviser. Form 13F comes from Section 13(f) of the Securities Exchange Act, which applies to any institutional investment manager: any entity, registered or not, that exercises investment discretion over the accounts of others or its own account above the threshold.
A family office that manages the family’s trusts, partnerships and foundations is exercising that discretion. Once the listed securities it controls reach $100 million, it files. The SEC staff’s own Form 13F questions and answers set out who counts and how discretion is attributed.
What counts, and when is it due?
- What counts toward $100 million. Only securities on the SEC’s quarterly official list of Section 13(f) securities: mostly US-listed shares and exchange-traded funds, certain options and warrants, and some convertible debt. Private funds, property, cash and most bonds do not count.
- When it is measured. On the last trading day of each month. Reaching the threshold in any one month of a calendar year creates the obligation for that year.
- The first filing. For the quarter ending December 31 of that year, due within 45 days, in mid-February. A deadline that lands on a weekend or federal holiday moves to the next business day.
- After that. At least the next three quarters, each within 45 days of quarter end, even if the listed book falls back under the threshold in the meantime.
- What follows from filing. A manager that files Form 13F also reports its say-on-pay proxy votes each year on Form N-PX. Counsel should confirm how both apply to the office’s own structure.
What does a family office’s 13F actually contain?
Less than the attention paid to them suggests. Across the 40 offices reviewed here, the middle filing in the newest quarter lists 16 names, and a quarter of them list 7 or fewer. It is a list of long listed positions on one day, published six weeks later, with no prices paid, no reasons and no return.
What should the office keep beside the filing?
The filing is the one page of the book a stranger can read, and it says what was held, never why. The reasons, the policy each position was judged against and who approved it stay inside the office, if they were written down at all. That record is what a successor, a trustee or a beneficiary’s counsel will ask for, and the filing will not supply it.
Short answers.
How is the $100 million threshold measured?
By the fair market value of the Section 13(f) securities the office has discretion over, on the last trading day of any month in a calendar year. Only securities on the SEC's official 13(f) list count: mostly US-listed shares, certain options and warrants, and some convertible debt. Private funds, property, cash, most bonds and direct holdings do not count toward it.
When is a family office's first Form 13F due?
Crossing the threshold in any month creates the obligation for that year. The first filing is for the quarter ending December 31 and is due within 45 days after it, in mid-February. The office then files for the next three quarters at least, each within 45 days of quarter end, even if the book falls back under $100 million.
Can a family office keep its 13F holdings confidential?
Only by asking. An office can request confidential treatment for specific positions, and the SEC grants it narrowly and for a limited time, typically for an acquisition or disposal still in progress. The default is public: the filing appears on EDGAR the day it is accepted.
What does a family office's 13F not show?
Most of the book. It lists long positions in listed 13(f) securities at quarter end, by share count and value. It shows no short positions, no cash, no private funds, no property, no debt, no cost basis and no return. For most families it is the smaller part of the balance sheet.
This page describes the rule in general terms and is not legal advice. Whether and how it applies to a particular office depends on how discretion is held across its entities; that is a question for securities counsel.
What the filings cannot tell you.
- Only listed shares held long are reported. Private funds, direct deals, property, cash, debt, fees and tax are all outside the filing.
- A filing is a photograph of one day, published up to 45 days later. It cannot show what was bought and sold in between.
- Only offices above the reporting threshold appear at all, so the cohort skews larger than the category.
- No prices are licensed here, so nothing in this cohort is a return, a ranking, or a backtest. Holdings facts only.
- An office under the threshold, or one whose listed shares are run by outside managers with their own discretion, files nothing and appears nowhere here.
How the cohort was assembled.
A screen proposed 51 filers as candidate family offices. A person read every one: 40 were accepted, 7 were rejected as something else, and 4 were left open because the evidence did not settle it. Only the accepted ones are in any figure on this page.
That is 874 filings and 61,471 reported positions across 22 quarters, each one read as of the day it became public rather than with the benefit of hindsight. A filing that arrived late is missing from its quarter instead of being back-filled into it.
The cohort is other firms' public quarterly filings, read as they stood on the day each one became public. It is not our clients, not their data, and not a performance record. Counts as at 19 September 2026.
Public filings only, and only the part of a book they cover: listed shares held long. No private holdings, no cash, no debt, no fees, no tax. Offices that stopped filing stay in every figure. Nobody here is named. Figures above are computed from the filings themselves, as they stood on 2026-09-20. A record and an analysis, not investment, tax or legal advice; decisions rest with the family and its advisers.