The SEC charged 11 institutional investment managers for failing to Form 13F file reports that they were required to file because they have discretion over more than $100 million in securities included on the SEC’s Official List of Section 13(f) Securities. Two of the entities were also charged with failing to file Forms 13H as required for large traders who transact in a significant amount of exchange-listed securities. Nine of the firms will pay more than $3.4 million in combined civil penalties. Certain firms were not ordered to pay civil penalties because they self-reported the violations at issue and otherwise cooperated with the SEC’s investigations. The case highlights the importance of actively monitoring relevant holding and trading thresholds that trigger Form 13F and 13H filings and recognizing that such filings may be applicable even if a firm does not routinely hold or trade Section 13(f) or exchange-listed securities.