13F-HR/A: StoneX Amends 13F Filing, Cites Under-Reporting Errors
Amendment to Holdings Report
StoneX Group Inc. filed an amended Form 13F-HR to correct significant under-reporting of securities, shares, and market values from Q4 2021 through Q1 2025 due to multiple internal errors.
Summary
- StoneX Group Inc. filed an amendment (13F-HR/A) to its Form 13F for the quarter ended December 31, 2021.
- The amendment, number 2, adds new holdings entries.
- An internal review revealed under-reporting of total securities, shares, and market values in quarterly filings from Q4 2021 through Q1 2025.
- The errors affected StoneX Advisors Inc., StoneX Financial Inc., and Trust Advisory Group, Ltd.
- Four main causes were identified: exclusion of three market making accounts, an Excel formula error ("XLOOKUP" instead of "SUMIF"), failure to implement an SEC rule change (rounding dollar values), and an Excel scientific notation error for CUSIPs with "E".
- The corrected Form 13F Information Table shows a total value of $31,429,579 across 37 entries.
Sentiment
Score: 3
Explanation: The sentiment is negative due to the discovery of significant, systemic, and prolonged under-reporting errors in regulatory filings, indicating weaknesses in internal controls and compliance. The proactive correction is a positive, but the underlying issues are concerning.
Positives
- The company proactively identified and is correcting significant reporting errors through an internal review.
- The amendment provides a more accurate representation of the firm's holdings.
Negatives
- Significant under-reporting of securities, shares, and market values occurred over an extended period (Q4 2021 through Q1 2025).
- Multiple systemic issues contributed to the errors, including missing accounts, incorrect Excel formulas, and failure to implement regulatory rule changes.
- The errors indicate deficiencies in internal controls and compliance procedures related to SEC reporting.
Risks
- Operational Risk: Deficiencies in data management and reporting processes, as evidenced by Excel errors and missing accounts.
- Compliance Risk: Failure to adhere to SEC reporting requirements, including the proper implementation of new rules (e.g., rounding dollar values).
- Reputational Risk: Inaccurate public filings can erode trust among investors and regulators.
- Regulatory Scrutiny: The identified errors could lead to increased scrutiny from the SEC regarding the firm's reporting practices.
Future Outlook
This filing is an amendment to correct past reporting errors and does not contain forward-looking statements or guidance regarding future business performance or financial outlook.
Management Comments
- "During an internal review of StoneX Group Inc.'s Section 13(f) reporting practices we discovered the quarterly filings from Q4 2021 through Q1 2025 under-reported the total number of securities, shares and market values."
- "The errors involved all Other Reporting Managers: StoneX Advisors Inc., StoneX Financial Inc., and Trust Advisory Group, Ltd."
Industry Context
This amendment highlights the critical importance of robust internal controls and accurate data management for institutional investment managers in meeting their regulatory reporting obligations, particularly for SEC Form 13F filings which provide transparency into significant equity holdings.
Comparison to Industry Standards
- Accurate and timely SEC reporting is a fundamental compliance standard for all institutional investment managers.
- The identified errors, such as reliance on flawed Excel formulas and failure to implement new regulatory rules, fall below industry best practices for data integrity and compliance automation.
- Leading firms typically employ sophisticated reporting systems and multi-layered review processes to prevent such systemic under-reporting errors over extended periods.
Corporate Governance
| Change Type | Description | Effective Date | Impact Assessment |
|---|---|---|---|
| Reporting Practice Review | An internal review of Section 13(f) reporting practices was conducted, leading to the discovery of under-reporting errors. | NA | Improved accuracy of regulatory filings and identification of systemic issues in data management and compliance procedures. |
| Compliance Procedure Failure | Failure to properly implement SEC Rule 87 FR 38943 regarding rounding dollar values in filings. | Q4 2022 | Led to inaccurate financial reporting for an extended period, highlighting a gap in regulatory compliance implementation. |
Stakeholder Impact
- Shareholders: Received inaccurate information regarding the firm's holdings for an extended period, potentially impacting investment decisions based on incomplete data.
- Regulators: The SEC relies on accurate filings for market oversight; these errors necessitate regulatory attention and potentially further scrutiny.
- Management: The errors reflect on the effectiveness of internal controls and compliance oversight, requiring immediate corrective action and potentially impacting reputation.
Next Steps
- Continued internal review and enhancement of reporting practices to prevent recurrence of similar errors.
- Potential follow-up or inquiry from the SEC regarding the identified compliance deficiencies.
Key Dates
| Date | Description |
|---|---|
| 12-31-2021 | Original report quarter ended date for the Form 13F being amended. |
| Q4 2021 | Start of period affected by missing market making accounts and Excel scientific notation error. |
| Q1 2022 | Start of period affected by Excel formula error. |
| Q4 2022 | Start of period affected by failure to implement SEC rounding rule. |
| Q4 2024 | End of period affected by missing market making accounts. |
| Q1 2025 | End of period affected by Excel formula error, failure to implement SEC rounding rule, and Excel scientific notation error. |
| 08-13-2025 | Signature date on the amended filing by John Calvano. |
Keywords
StoneX Group, SEC Filing, 13F Amendment, Holdings Report, Investment Management, Compliance Errors, Financial Reporting, Under-reporting, Regulatory Compliance, Market Making Accounts, Excel Errors, CUSIP
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