Combined 13F Filings and Multiple Managers

A combined 13F filing is the SEC's anti-duplication mechanism for affiliated or shared-discretion managers. When more than one institutional manager has a 13F reporting obligation over the same securities, the group should not make investors count the same Apple, Microsoft, or Nvidia shares twice. Instead, one Form 13F-HR can report the holdings, while related managers either appear as other included managers on that report or file a Form 13F-NT notice pointing readers to the reporting manager.

That distinction matters on 13F Insight because the platform tracks both holdings reports and notices. The database includes 128K+ Form 13F-NT filings, and a notice normally has $0 reported value and 0 holdings because it is a cover-page filing, not an empty portfolio call. For example, TOKIO MARINE HOLDINGS, INC. filed a Form 13F-NT for the 2026-03-31 report period, accession 0001172661-26-002460, with no holdings rows on its own filer page.

The investor takeaway is simple: a 13F-NT is not a bearish signal, a liquidation, or proof that a manager stopped managing money. It is usually a routing signal. To understand the actual securities, look for the related Form 13F-HR or combination report that carries the information table.

The three 13F reporting paths

The SEC recognizes three practical ways to file Form 13F when managers have reportable Section 13(f) securities:

Report type	EDGAR submission type	What it means for readers
13F Holdings Report	13F-HR	The filer reports all of its 13F securities in its own information table.
13F Combination Report	13F-HR	The filer reports some securities itself and identifies another manager that reports the rest.
13F Notice	13F-NT	The filer reports no holdings table because all of its 13F securities are reported by another manager.

The confusing part is that a combination report still uses the EDGAR submission type 13F-HR. The word "combined" is a reporting concept on the cover page and summary, not a separate EDGAR form type you can always filter by name. A 13F-NT, by contrast, is visibly labeled as a notice and should not contain an information table.

Why multiple managers can share one holdings report

Large financial groups often have parent companies, registered advisers, sub-advisers, affiliated managers, or control relationships that create overlapping 13F reporting duties. If two managers share investment discretion over the same securities, both can have an obligation to report, but duplicate rows would make market-wide ownership look larger than it is.

Combined reporting solves that problem. One manager files the holdings table, while the other manager is identified so readers know where the securities are being reported. In some cases, the non-reporting manager files a 13F-NT notice. In other cases, the reporting manager's 13F-HR lists other included managers on the cover page or summary page.

This is where the investment discretion codes become useful. SOLE, DFND, and OTR help describe who has discretion over a position. They are not buy or sell signals; they are ownership-control labels that help prevent readers from treating organizational structure as portfolio conviction.

How to read a 13F-NT on 13F Insight

When a filer page shows a recent Form 13F-NT with no holdings, read it in this order:

1. Check the form type. 13F-NT means notice. A missing holdings table is expected.
2. Check the reported value and holdings count. A notice should normally show $0 reported value and 0 holdings on the notice filer because the securities are elsewhere.
3. Look for the reporting manager named by the notice. The actual positions should be on another manager's Form 13F-HR.
4. Avoid treating the notice as a full exit. A manager can file a notice while its reportable securities still appear under a parent or affiliate's holdings report.
5. Use the platform's filings list as a routing tool. The SEC filings feed helps separate 13F-HR holdings reports from 13F-NT notices before you interpret the portfolio.

If you are researching overlapping institutional ownership, the Combined Holdings tool can be more useful than comparing one filer page at a time. It is designed for cases where the investment question is about combined exposure, not a single legal entity's cover-page filing.

13F-NT vs 13F-HR vs 13F-HR/A

A 13F-HR is the filing investors usually mean when they say "a 13F." It contains the information table: issuer name, class, CUSIP, market value, share count, investment discretion, voting authority, and any other-manager references.

A 13F-NT is different. It is a notice that tells readers the filer's 13F securities are reported on another manager's 13F. It does not list the securities itself. That is why a 13F-NT can look empty on a data platform even when the economic exposure exists in a related filing.

A 13F-HR/A is an amendment to a holdings report or combination report. It may correct, add, or restate information. If the issue is an amended holdings table, use the amendment framework in 13F-HR/A amendments. If the issue is a notice with no table, treat it as a 13F-NT routing question instead.

Common mistakes when interpreting combined 13F filings

• Mistake 1: counting affiliated reports twice. If one manager reports for another, adding both pages mechanically can overstate exposure.
• Mistake 2: calling a notice an exit. A 13F-NT says the holdings are reported elsewhere; it does not say the manager sold everything.
• Mistake 3: assuming every 13F-HR is standalone. Some 13F-HR filings are combination reports, so the cover page and other-manager references matter.
• Mistake 4: ignoring filer type. Passive index funds, custodians, and affiliated managers can appear for structural reasons. Their filings should not automatically be framed as hedge-fund conviction.

Practical workflow for investors

Use 13F-NT and combined-report clues as a data-cleaning step before drawing investment conclusions. First, identify whether the page is showing a holdings report, a notice, or an amendment. Second, find the reporting manager that carries the actual information table. Third, compare the real holdings history only after you know which entity is the portfolio-reporting entity.

That workflow is less exciting than scanning top buys, but it prevents one of the easiest 13F mistakes: mistaking legal-entity plumbing for investment behavior. A notice filing often says "look over there," not "nothing happened."

FAQ

What is a combined 13F filing?

A combined 13F filing is a Form 13F-HR where one manager reports securities for itself and another related manager, or reports some positions while another manager reports the rest. It prevents duplicate reporting when managers share investment discretion.

What is the difference between 13F-HR and 13F-NT?

13F-HR is a holdings report with an information table. 13F-NT is a notice filing that usually has no holdings table because all of the filer's 13F securities are reported by another manager.

Does a 13F-NT mean a fund sold all its stocks?

No. A 13F-NT usually means the filer's holdings are reported on another manager's Form 13F. It should not be read as a liquidation unless other evidence shows the positions actually disappeared.

Why do affiliated managers file separate 13F notices?

Affiliated managers may each have a 13F reporting obligation because of shared investment discretion or control relationships. A notice identifies that the holdings are being reported by another manager instead of duplicated.

How can investors find the holdings behind a 13F-NT?

Investors should read the notice for the manager named as reporting the securities, then review that manager's Form 13F-HR. On 13F Insight, start with the filer page and filings feed to locate the related holdings report.

Is a 13F combination report the same as a 13F-NT?

No. A 13F combination report is filed as 13F-HR and includes at least some holdings. A 13F-NT is only a notice because the filer reports none of its securities on that filing.

Why does a 13F-NT show zero holdings on 13F Insight?

It shows zero holdings because the notice filer is not submitting an information table. The relevant positions should appear on another manager's 13F-HR, so the zero count is a routing clue rather than a portfolio signal.