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Every ETF that relies on the SEC's Rule 6c-11 must post its full portfolio holdings on its website every business day, before trading opens (FilePoint, 2025). Institutions managing $100 million or more in U.S. securities must also disclose their long positions to the SEC each quarter (Dakota Holdings). That is a lot of free data.
The catch is that free data answers only part of the question. This guide breaks down what each free source gives you, where it runs out, and when a paid source is worth it.
Two Kinds of ETF Holdings Data
"ETF holdings" means two different things, and the right source depends on which one you need.
Fund holdings show the securities inside an ETF. Product teams and analysts use them to compare baskets and see exposure.
Ownership holdings show which institutions own shares of the ETF. Sales teams use them to find prospects who already invest in their category.
Free Sources
Issuer Websites
Under Rule 6c-11, each ETF must publish its daily holdings, including ticker, identifier, description, quantity, and percentage weight (CBIZ, 2024). This is the freshest free view of what is inside a fund, and it is the best place to check a competitor's basket.
It does not cover every ETF. Non-transparent ETFs do not disclose holdings daily and cannot rely on the rule (Seward & Kissel, 2019).
SEC Form N-PORT
Registered funds, including ETFs, report position-level portfolio data to the SEC on Form N-PORT. The SEC publishes N-PORT data sets through its open data catalog. It is a good free source for historical fund holdings, but it arrives with a lag, so it is not a daily view.
SEC Form 13F
Form 13F is the main free source for ownership. The SEC publishes 13F data sets quarterly, extracted from filings and presented as filed (SEC). Filings are due 45 days after each quarter ends and cover long positions only (Dakota Holdings).
If you want to know who owns a given ETF, this is where the answer starts.
Where Free Data Runs Out
Free sources tell you what someone owned. They stop short of telling you what to do about it.
- The lag: A 13F is public 45 days after quarter end, so the data is already stale when it appears.
- The format: Data sets are flat files presented as filed, and the SEC says it cannot guarantee their accuracy (SEC). Positions are reported by issuer name and CUSIP, so you have to match them to tickers yourself.
- The missing context: A filing does not tell you who to call, how to reach them, or how a holding fits the firm's mandate.
- The missing structure: There is no asset class taxonomy, so you cannot filter by sub-asset class without building your own.
Turn 13F filings into a call list. Dakota Marketplace tracks more than 900,000 ETF holdings, matched to the firms that own them and linked to confirmed contacts. Book a demo to see who holds your ETF category.
Paid Sources
Paid sources fall into three groups.
Market data and fund research platforms are built for analysis. They are strong on fund-level holdings, exposure, and fees, but generally not on who to call at the firms that hold a fund.
Advisor and RIA databases add firm-level detail on the advisors who buy ETFs.
Sales intelligence platforms combine holdings with firm profiles and contacts, so a holding turns into an outreach list. Dakota Marketplace is in this group.
What Dakota Adds
Dakota ingests every 13F daily and enriches it before it reaches your team (Dakota). Dakota Marketplace tracks more than 2 million 13F investments, including more than 900,000 ETF holdings (Dakota Marketplace).
Every position is categorized across 19 asset classes and 236 sub-asset classes. Each filing is matched to a known firm and linked to confirmed contacts (Dakota Holdings).
Dakota tracks more than 6,000 accounts that file 13F reports, more than 3,000 of them RIAs (Dakota Marketplace), with roughly 47,000 verified contacts at RIA accounts (Dakota Marketplace). Everything flows into Salesforce, HubSpot, Backstop, or DealCloud.
Free vs. Paid: How to Choose
Free sources are enough if you need to see what is inside a fund, check a competitor's basket, or pull a handful of filings for one-off research. The cost is your time.
A paid source pays off when the goal is outreach. If your team needs to find every institution holding a competing product, rank them by position size, and call the right person, you need holdings, firm context, and contacts in one place. Free data gives you the first. Paid data gives you all three.
Know Who Holds Your Category Before You Call
Dakota Marketplace tracks more than 900,000 ETF holdings, linked to confirmed contacts at the firms that own them. Filter by:
- ETF ticker, asset class, and sub-asset class
- Active or passive ETF AUM
- Filer type: RIA, wealth platform, bank, or family office
- Filing period and position size
Free data tells you what institutions own. Dakota tells you who to call. Book a demo to see ETF holdings data in action.
