Mistakes happen. Therefore, the SEC accepts amended filings. We looked our database of all filings since 2014, more than seven million. We found more the 600,000 amended filings. Thus nearly one in ten filings is an amendment. Of course these amended filings are not uniformly distributed.
It is easy to think of amendments as errors and, therefore, the relative frequency of amended filings as the error rate. That may not be the best term. But amending a filing consumes resources, so there is something wrong.
Which filings are most amended?
The chart below shows the amended ratio (amended:non-amended) for the 33 forms that have at least 10,000 non-amended filings.
The forms are ordered from greatest ratio to least (top to bottom). The ratio and the count of the non-amended filings are to the right of the bars.
Two filings stand out
Obviously, what stands out most are Forms SC 13D and SC 13G. Their ratios are greater than one, which implies that many of the filings were amended more than once.
| Form | Non-amended | Amended | Ratio | Description |
|---|---|---|---|---|
| SC 13D | 13,221 | 41,683 | 3.2 | General statement of acquisition of beneficial ownership |
| SC 13G | 71,497 | 178,765 | 2.5 | Statement of acquisition of beneficial ownership by individuals |
Table above list the counts of the filings to date.
Examples from EDGAR:
Forms 4 (Statement of changes in beneficial ownership of securities) and 5 (Annual statement of changes in beneficial ownership of securities) also disclose ownership. However, these filings have an amended ratio of 2%.
Form D
If it were not for the outrageous ratios just discussed, one might be surprised by the 0.62 ratio of Form D (Notice of Exempt Offering of Securities).
Annual report
The amended ratio for annual reports (Form 10-K) is 13%. This both surprising because of the time and effort put into creating the document and not surprising due the amount of information in the filing. No doubt the large number of eye balls scouring over the filing contributes to finding mistakes. Coders understand that "with enough eyeballs, all bugs are shallow" ref.
The quarterly report, which is similar to the annual report, has far fewer amendments.
Holdings reports
Forms NPORT-P and 13F-HR both reports the holdings in funds. The former is filed for mutual funds and ETFs. The latter is filed for independent advisors. The amended ratio for 13F-HR is 3 times greater than for the NPORT-P (5.4% to 1.7%). We will not opine on the relative care given these filings.
