Form 13F Reporting Requirements - Advisor Solutions Group

COMPLIANCE UPDATE

Form 13F Reporting Requirements

Who Must File Form 13F

Institutional investment managers that use the United States mail (or other means or instrumentality of interstate commerce) in the course of their business and that exercise investment discretion over $100 million or more in Section 13(f) securities must file Form 13F. An institutional investment manager is an entity that either invests in, or buys and sells, securities for its own account, or a natural person or entity that exercises investment discretion over the account of any other natural person or entity. A trustee is an institutional investment manager, but a natural person who exercises investment discretion over his or her own account is not an institutional investment manager.

Institutional investment managers who exercise investment discretion over $100 million or more in Section 13(f) securities and utilize sub-adviser(s) should review their sub-advisory agreements to determine who is responsible for Form 13F filings, and may need to file a 13f notice indicating that other reporting managers report holdings.

What Securities to Report on Form 13F

Section 13(f) securities are equity securities of a class described in Section 13(d)(1) of the Securities and Exchange Act. See Section 13(d)(1) of the Securities Exchange Act. Generally, the list includes exchange-traded (e.g., NYSE, AMEX) or NASDAQ-quoted stocks, equity options and warrants, shares of closed-end investment companies, and certain convertible debt securities. Shares of open-end investment companies (i.e., mutual funds) are not included and, therefore, should not be listed on Form 13F. Shares of exchange-traded funds ("ETFs"), however, are on the Official List and should be reported.

Below is a summary of which securities to include or exclude from the report. Only report securities that are on the Official List of Section 13(f) Securities. You should always check the SEC web site at the end of each quarter for the current list of 13(f) securities: .

Securities, generally

Foreign Issuer

Short positions

Loaned securities Options (calls and puts) Warrants

Include

o Securities on Official List of

Section 13(f) Securities

o Positions as of trade date (not

settlement date)

o Only if traded on US exchange or

quoted on NASDAQ

o Securities loaned to a third party

o Options held

o Warrants held

Exclude

o Securities not on the Official List o Positions less than 10,000 shares and

holdings of under $200,000 (both requirements must be met)

o "Pink sheet" ADRs o Securities traded on non-US

exchanges

o Short positions; do not subtract short

positions from long positions in same security (report only long position)

o Securities borrowed from a third

party

o Options written (e.g., short positions

are not reported)

(Tip: When searching for a certain holding on the 13(f) list by CUSIP number, exclude the last three digits. The Official List includes spaces after the sixth digit that will not be picked up by entering the entire nine-digit number.)

? 2006 Advisor Solutions Group, Inc.

Page 1 of 2

Revised January 2011

Form 13F requires disclosure of the names of institutional investment managers, security name, class of security, CUSIP number, number of shares owned, and the total market value of each security.

When to File Form 13F

Form 13F must be filed no later than 45 days after the end of the March, June, September, and December quarters. If the filing deadline falls on a weekend or a holiday, then your filing is due on the next business day.

(Tip: The filing deadlines are Eastern time. Managers in other time zones should note that filings submitted after 5:30 p.m. Eastern time will receive a filing date of the next business day.)

Initial Filing For first-time filers, if you reach $100 million in 13(f) securities as of the last trading day of any month during a calendar year, you must file your first Form 13F report for the December quarter of that year (within 45 days after the end of the quarter). You will then need to submit filings for the three subsequent quarters (March, June, and September) of the following calendar year, even if the market value of your Section 13(f) securities falls below $100 million.

Final Filings You must submit filings for the first three quarters of the calendar year following the year in which the market value of your Section 13(f) securities falls below the $100 million level.

For example, if you had 13(f) securities >$100MM on November 30, 2010, but $100MM on April 30 (or any other month-end) of 2011, you would continue to file for the December 2011 quarter-end and for the first three quarters of 2012.

How to File Form 13F

Form 13F must be filed electronically using the SEC's Electronic Data Gathering, Analysis and Retrieval (EDGAR) system. To file through EDGAR yourself, you will need a Form ID, the EDGAR Filer Manual, and EDGARLink software, all of which are available through the SEC's website.

Various service providers also provide Form 13F filing assistance. A sample list of vendors is provided below. This list is provided for informational purposes only. Advisor Solutions Group, Inc. does not endorse these firms or have any affiliation with them.

EDGARfilings Merrill Corporation SecureX Filing Corp

(Tool: The SEC puts out the 13F list every quarter in pdf format. To make searching easier, consider utilizing software that converts pdf to Excel, such as PDF2XL from Softpedia: .) This is not an endorsement, and applications from other vendors are also available.

Additional SEC Guidance

The SEC's Division of Investment Management has responded to Frequently Asked Questions about Form 13F at .

For more information regarding Form 13F filing requirements, please contact:

Advisor Solutions Group, Inc. 949.250.1855 info@

1300 Bristol Street North | Suite 100 | Newport Beach, CA 92660 | 949.250.1855



? 2006 Advisor Solutions Group, Inc.

Page 2 of 2

Revised May 2012

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