For a Form 13F, use the nine-character CUSIP from the SEC Official List applicable to the reporting quarter—not automatically the identifier shown in a current lookup. A later corporate action can introduce a new CUSIP after quarter-end, making that newer identifier wrong for the historical report. FIGI is optional and supplemental; it does not replace CUSIP. For an option position, SEC guidance directs filers to use the underlying security’s CUSIP.
What is the CUSIP problem with 13F filings?
The difficulty is one of timing and security identity. A CUSIP that is valid now may not be the right identifier for a 13F reporting an earlier quarter. If a filer maps a historical holding using an identifier introduced by a later corporate action, the Information Table can misidentify the holding for that period.
A specific example appears in a Q1 2026 Form 13F amendment filed May 15, 2026. The reporting manager said an issuer conversion effective April 20, 2026 created a new CUSIP after the reporting period; that later CUSIP had been included in the original filing, resulting in the security being inadvertently excluded. This is one filer’s explanation in one amendment, not evidence of how often such errors occur. Read the amendment.
Which CUSIP should I use for a 13F filing?
Use the nine-character CUSIP on the SEC Official List for the calendar quarter being reported, matching the issuer and security class. The SEC’s Q2 2026 list information sheet says that list is current as of June 30, 2026 and may be relied upon for filings for that calendar quarter. The SEC publishes updated lists quarterly, so select the period-specific list rather than assuming a present-day identifier applies to a historical report. See the Q2 2026 Official List information sheet.
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Do not search by ticker or current company name alone. The issuer may have multiple classes or instruments, and names and identifiers can change. Keep issuer, class, reporting period, and effective-date context with each mapping so a plausible match is not mistaken for the correct security.
Can I use FIGI instead of CUSIP on Form 13F?
No. Form 13F Information Table Column 3 requires a nine-character CUSIP. A filer may also enter a twelve-character FIGI, but it is additional information, not a substitute. The SEC’s Division of Investment Management FAQ describes FIGI as usable “in addition to, but not instead of” CUSIP. That FAQ reflects staff views and expressly is not a Commission rule or regulation. Read the SEC Form 13F FAQ and current Form 13F instructions.
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How do you report options on Form 13F?
For a 13F option position, use the CUSIP of the underlying security, as stated in SEC staff guidance and the Q2 2026 Official List information sheet. The list may show individual listed options with their own CUSIPs; those entries do not change the instruction for identifying an option holding in the 13F Information Table. Check the underlying issuer and class, then apply the quarter-specific list.
A practical quarter-by-quarter reconciliation
- Fix the reporting period. Record the calendar quarter end for the report before looking up identifiers.
- Open the matching SEC Official List. Use the list applicable to that quarter, not simply the newest list available.
- Match the security. Search and verify issuer and class, retaining both in your internal mapping rather than relying on a ticker or company name alone.
- Enter the CUSIP. Confirm the required nine characters against the period-specific list. If you include a FIGI, treat it only as an additional twelve-character field.
- Apply the option rule where relevant. Use the underlying security’s CUSIP for an option position.
- Review later corporate actions. If your workflow presents a newer identifier, check its effective date against quarter-end before substituting it.
- Validate the whole filing. Check the Information Table against current EDGAR requirements and confirm the other required filing components are present.
What else must be complete in the filing?
The Information Table is not the entire Form 13F submission. The SEC describes the filing as comprising a Cover Page, Summary Page, and Information Table; its FAQ says a submission containing only the Information Table is incomplete and should be amended. The SEC’s Excel/XML guide can help with field construction and length checks, but its workflow is older, so consult current form and EDGAR specifications for filing requirements. See the SEC XML Information Table guide.
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