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For a Form 13F, use the nine-character CUSIP that matches the security and the reporting quarter—not automatically the identifier currently shown in a database. The SEC publishes a quarterly Official List of Section 13(f) Securities for this purpose. A FIGI may be added, but it cannot replace the 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 temporal as well as logistical: a security’s identifier can change after the quarter being reported. If a filing workflow substitutes a later CUSIP for the one applicable to the reporting period, a holding can be mismatched or omitted. A ticker or current issuer name alone does not resolve that question, because the record also needs to identify the correct class and period.
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A specific example illustrates the risk without establishing how often it occurs. In a Form 13F amendment filed May 15, 2026, a reporting manager said an issuer conversion effective April 20, 2026 created a new CUSIP after the Q1 reporting period. The new CUSIP had been included in the original Q1 filing, resulting in the security being inadvertently excluded. That is the filer’s explanation of one amendment, not a general SEC finding or a measure of error frequency. Read the SEC-filed amendment.
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Use the nine-character CUSIP for the security as identified on the SEC Official List applicable to the calendar quarter being reported. For example, 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. It is not a general substitute for the list applicable to another quarter. See the Q2 2026 Official List information sheet.
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Form 13F Information Table Column 3 calls for the CUSIP. The SEC’s form instructions specify nine characters for that field. Confirm the issuer and class as well as the identifier: a company name or ticker by itself may not distinguish among its securities. The SEC’s Form 13F provides the filing instructions.
Can I use FIGI instead of CUSIP on Form 13F?
No. FIGI is optional and supplemental. The SEC Division of Investment Management’s staff FAQ describes the 2022 form amendments as adding the option to use a FIGI “in addition to, but not instead of” the CUSIP. The form instructions specify twelve alphanumeric characters for an entered FIGI. A FIGI therefore does not fix a missing or incorrect CUSIP. The FAQ reflects staff views; it is not a Commission rule or regulation. Read the SEC staff FAQ.
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How do you report options on Form 13F?
For an option holding, use the CUSIP of the underlying security, according to both the SEC staff FAQ and the Q2 2026 Official List information sheet. The Official List may also show individual listed options with their own CUSIPs; those entries do not change the SEC’s instruction for identifying an option position in the 13F table.
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How to reconcile 13F identifiers by reporting period
- Fix the period. Determine the calendar quarter end for the report before looking up an identifier.
- Use that quarter’s Official List. Search using issuer and class information, rather than relying only on a ticker or a current company name.
- Verify the CUSIP. Confirm the nine-character value and retain issuer/class context in your internal mapping so different securities are not collapsed into one record.
- Keep identifier roles distinct. Enter the CUSIP as required; include a FIGI only as an optional additional identifier.
- Apply the option rule. For a listed option position, use the underlying security’s CUSIP.
- Check later corporate actions. If a newer identifier appears in the workflow, compare its effective date with the report’s quarter before using it.
- Validate the whole filing. Check the Information Table fields and current EDGAR requirements, and confirm the required filing components are present.
Why the Information Table alone is not a complete filing
Form 13F includes a Cover Page, Summary Page, and Information Table. SEC staff FAQ guidance says that submitting only the Information Table is incomplete and should be amended. The SEC’s XML Information Table guide describes an Excel-based workflow, but its field checks should be treated as corroboration rather than a replacement for current filing instructions and EDGAR specifications.
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