BNY Mellon Files 33,186 Positions in Its Q4 13F — More Than Any Other Filer in Our Database. Here's What the Oldest U.S. Bank Reveals About the Market.

Bank of New York Mellon was founded by Alexander Hamilton in 1784 — eleven years before the New York Stock Exchange opened. Two hundred and forty-one years later, BNY Mellon's Q4 2025 13F filing lists 33,186 distinct equity positions worth $568 billion. That's more positions than any other filer in our database, including banks twice its size.

The reason is BNY Mellon's unique role in the financial system. It's the world's largest custody bank, safeguarding $47 trillion in assets for other institutions. Its investment management arm — which includes the Dreyfus fund family, Insight Investment, Newton Investment Management, and Mellon Investments — generates the 13F filing we're analyzing. But the extreme position count reflects the aggregate of dozens of sub-advisors, each running distinct strategies.

33,186 Positions: What That Number Means

To put the position count in perspective:

• Bank of America: 28,105 positions ($1.375T AUM)
• JPMorgan Chase: 31,783 positions ($1.59T AUM)
• BNY Mellon: 33,186 positions ($568B AUM)
• Wells Fargo: 17,860 positions ($549B AUM)

BNY Mellon has more line items than JPMorgan despite being less than half its size. This inverse relationship — smaller AUM, more positions — is the custody bank signature. BNY Mellon's sub-advisors run everything from large-cap growth to micro-cap value to international equity to fixed-income hybrids with equity components. Every individual security in every sub-advised strategy appears as a separate line item.

The Top 5: Standard Mega-Cap, Higher Concentration

Despite the extreme breadth, BNY Mellon's top 5 is the standard mega-cap tech order: NVIDIA ($29.5B), Apple ($26.6B), Microsoft ($26.3B), Amazon ($15.8B), Alphabet ($13.1B). The top-5 concentration is 22.4% — the highest of any mega-filer we've profiled this quarter.

The concentration is counterintuitive given the 33K position count, but it makes sense: BNY Mellon's largest sub-advisors (particularly Mellon Investments, which runs index strategies) have massive mega-cap allocations that dwarf the thousands of smaller positions in specialty funds.

The Alphabet Consensus — Confirmed Again

BNY Mellon provides perhaps the cleanest confirmation of the Q4 Alphabet consensus trade. GOOGL shares grew 1.6%, and combined GOOGL + GOOG value jumped $4.97B to $22.3B. This makes Alphabet the 4th largest effective holding when both share classes are combined.

We've now documented this pattern at Fidelity, Morgan Stanley, Goldman Sachs, BofA, Invesco, Schwab, Wellington, and now BNY Mellon. Every single major institutional filer increased their Alphabet allocation in Q4 2025.

Berkshire Hathaway in the Top 15

A distinctive BNY Mellon feature: Berkshire Hathaway Class B (BRK/B) at $5.6B in the 12th position. This is unusual among the mega-filers we've covered — most don't hold meaningful Berkshire positions because it's not a natural index component at scale (Berkshire doesn't pay dividends and doesn't issue many shares).

BNY Mellon's Berkshire holding likely comes from its value-oriented sub-advisors and income-focused strategies that view Berkshire as a diversified conglomerate at an earnings discount. At $5.6B, it's larger than Lilly, J&J, or any individual bank stock in the portfolio.

The iShares Anchor: $9.2B in IVV

BNY Mellon holds $9.2B in iShares Core S&P 500 (IVV) — making it the 9th largest position. This is pure index allocation, likely from the Mellon Investments passive strategies and BNY Mellon's own model portfolios. Unlike Bank of America's SPY-to-IVV rotation, BNY Mellon appears to have been an IVV shop all along.

Steady Hands: Minimal Q4 Changes

The most remarkable feature of BNY Mellon's Q4 filing is how little moved:

• NVIDIA: +0.9% shares (essentially flat)
• Apple: +0.4% shares
• Microsoft: -1.7% shares (mild trim)
• Amazon: -1.8% shares
• IVV: +0.3% shares

This stability is the custody bank model in action. Most of BNY Mellon's AUM is in index strategies and broadly diversified portfolios that don't make large tactical shifts. The 33,186 positions each moved a fraction of a percent — thousands of tiny adjustments that sum to near-zero net change.

How BNY Mellon Fits the Institutional Landscape

Among the filers we've profiled, BNY Mellon occupies a specific niche:

• Most positions: 33,186 — reflecting its multi-boutique investment management structure
• Highest top-5 concentration: 22.4% — index strategies dominate the aggregate
• Least active change: Near-zero QoQ adjustments across top holdings
• Unique holdings: Berkshire Hathaway and Exxon Mobil in the top 15, reflecting value sub-advisors

If Wellington represents what pure active managers think, BNY Mellon represents what the broadest possible institutional consensus looks like. Its filing is a weighted average of dozens of investment philosophies — and the result looks remarkably close to the market itself.

What Investors Should Watch

• Stability is the signal: When 33K positions barely move, it means no major institutional rotation is underway
• Eli Lilly surge: $5.5B, up from $3.9B, with flat shares — pure price appreciation. The GLP-1 trade is now in every institutional portfolio.
• JPMorgan as a holding: $7.6B, with shares growing 5.4% — a rare active build in a mostly static portfolio
• Exxon at $5.6B: Energy maintaining its weight in value-oriented strategies — no signs of ESG-driven divestment at the custody bank level