Shared discretion on 13F: one holdings row can name several managers

Berkshire Hathaway’s June 30, 2026 information table lists Ally Financial on six rows totalling 27 million reported shares. One of those rows carries 2,803,875 shares and three other-manager designations: 2, 4 and 11. Those three references do not turn its share quantity into three separate blocks.

For an institutional data team combining related managers’ disclosures, this creates two different counting risks. Removing rows merely because their security identifiers match can discard reported quantities. Expanding each row into a separate record for every linked manager, then adding those records, can count the same reported block repeatedly. The filing’s reporting relationships determine which document to use; its row structure determines how to count within it.

Follow the notice to the reporting table#

National Indemnity’s notice, accession 0001193125-26-352238, was filed August 14, 2026 for June 30. It identifies itself as a 13F NOTICE, gives its own file number as 028-00718 and names Berkshire Hathaway, file 28-4545, as the other reporting manager.

The corresponding Berkshire cover, accession 0001193125-26-352200, is a 13F HOLDINGS REPORT filed on the same date for the same quarter. Its own file number is 028-04545. Its summary lists 14 other included managers and 89 information-table entries. National Indemnity appears as included manager 11, with file number 28-718.

The references work in both directions. National’s notice points to Berkshire’s reporting file; Berkshire’s included-manager list points back to National. The numeric segments reconcile 28-4545 with 028-04545 and 28-718 with 028-00718 while preserving the original strings. That is a specific filing-based relationship, stronger than matching company names or observing similar portfolios.

The SEC staff FAQ, questions 33 and 34, explains why the distinction matters. A notice is a cover-page filing used when the manager’s reportable securities are reported elsewhere, and its other-manager list directs readers to that report. National’s captured submission contains no separate information table to add to Berkshire’s. It should remain a linked notice in the research record, rather than become an empty independent portfolio or an extra copy of the reporting table.

One Ally row, three manager references#

In Berkshire’s information table, all six Ally rows name ALLY FINL INC, class COM, CUSIP 02005N100. Each uses quantity type SH and discretion code DFND. Their other-manager combinations differ: examples include 2,4,11; 4,8,11; and 4,11. A shared CUSIP therefore does not make the six source rows interchangeable.

The 2,803,875-share row is the clearest example. Its other-manager field is 2,4,11, and the cover maps 11 to National Indemnity. FAQ 48 explains that these numbers refer to the numbered manager list on the summary page and link the reported securities to those managers. They are filing-local designations, not CIKs or three additional share quantities.

An attribution view may legitimately associate that row with each of the three managers. But returning from that view to the report’s holdings requires counting its original share block once. The quantity belongs to the source row; the list describes its managerial attribution. Multiplying 2,803,875 by the number of references would answer neither the row’s reported quantity nor its share of the table.

Adding the six original Ally quantities produces 27,000,000 reported shares in this table. That is arithmetic over six source rows, not a reconstruction of six independent beneficial owners. Nor is it a calculation of National Indemnity’s entire Ally position or an assertion about either firm’s present holdings.

Keep attribution separate from counted holdings#

The practical distinction is between removing a duplicate copy and aggregating distinct reported rows. Preserve the reporting accession and original row identity alongside the quarter, security class, CUSIP, quantity type, discretion code and manager references. Keep the notice-to-report relationship separately. A group-level view can then resolve the reporting chain without losing the row detail needed for a manager-attribution view.

Matching holdings alone supplies no such reporting chain. When an explicit relationship is missing, retain the separate records and the unresolved relationship rather than infer shared reporting from a familiar issuer or quantity. Instrument identity needs its own treatment too: the Citadel option-row analysis shows why matching underlying-security identifiers do not make every row the same instrument.

This case uses two original August filings about June 30 and the related Berkshire table. It does not exhaust later amendments, all affiliated filings or economic ownership. Its useful consolidation is narrower: follow the documented reporting link, retain all six reported Ally rows and prevent their manager-reference lists from multiplying the quantities already disclosed.