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Vic Chen
Vic Chen

Posted on • Originally published at 13finsight.com

BNY Mellon's $568B Portfolio Mirrors the S&P 500 Perfectly — Except for Berkshire at #12

Bank of New York Mellon's Q4 2025 13F looks like a photocopied S&P 500 — NVDA, AAPL, MSFT, AMZN in the expected order. Then you reach position #12: Berkshire Hathaway (BRK/B) at $5.6 billion.

Berkshire at #12 in an otherwise pure index-mirror is the most interesting deviation in one of the most boring filings in the database.

The filing

Metric Value
13F AUM $568B
Top holdings NVDA, AAPL, MSFT, AMZN — standard S&P 500 order
Notable deviation BRK/B at #12 ($5.6B)
IVV (S&P 500 ETF) Also in top holdings
Overall character Index-mirror with a tilt

Why BNY Mellon's filing looks like the S&P 500

BNY Mellon is the world's largest custodian bank. Their 13F reflects:

  1. Index fund management: BNY Mellon Wealth Management runs index and quasi-index strategies
  2. Custodial aggregation: Some reported positions may include assets held in custody
  3. Institutional client mandates: Managing money for pension funds, endowments, and foundations that typically want benchmark-like exposure

The result: a top-10 that is virtually indistinguishable from the S&P 500 weights.

The Berkshire deviation

Berkshire Hathaway at position #12 with $5.6B is notable because:

Where BRK sits in the S&P 500

Berkshire is typically around #7-10 in the S&P 500 by weight. At #12 in BNY's filing, it could be:

  • Slightly underweight vs. index (positions 7-11 pushed it down)
  • Or at index weight but bumped by other holdings that are slightly overweight

Why BRK stands out

In an otherwise perfectly index-like filing, ANY deviation is worth noting. BRK at #12 could reflect:

  1. Active tilt toward Buffett: BNY Wealth Management may deliberately overweight BRK as a "quality value" conviction — a stock that provides market exposure with a value tilt
  2. Client preference: Institutional clients may specifically request BRK exposure (it's a common "proxy for the market with Buffett's judgment" allocation)
  3. Custodial artifact: BNY holds Berkshire shares in custody for various institutional clients, which might aggregate into the 13F

The custodian bank 13F pattern

Custodian banks file some of the most index-like 13Fs because their business model IS the index:

Custodian 13F AUM Deviation from S&P 500
BNY Mellon $568B Minimal — BRK at #12 is notable
State Street $3.4T Minimal — pure index manager
Northern Trust $1.2T+ Minimal — wealth + custody

How to read custodian filings

  • Top 10 matches S&P 500: Expected. No signal.
  • Small weight deviations (±0.5%): Could be timing, rebalancing, or fund composition differences
  • A stock appearing outside expected index position: This is where the signal lives
  • ETF holdings (IVV, SPY): Reflects internal fund-of-funds or client collateral

The IVV holding

BNY Mellon also holds iShares S&P 500 ETF (IVV) — which is a BlackRock product. A custodian bank holding a competitor's ETF alongside individual stock positions suggests:

  • Some client mandates use ETFs for core exposure
  • IVV may be used as collateral or for cash management
  • The ETF sits alongside individual stock positions that replicate the same index (double exposure to the same names through different vehicles)

What BNY's filing tells you

About the market

  • The S&P 500's top-heavy structure is so dominant that even a $568B custodian bank's portfolio is essentially a capitalization-weighted mirror
  • NVDA, AAPL, MSFT, AMZN dominate every institutional portfolio regardless of the manager's DNA

About BNY Mellon specifically

  • Their wealth management arm runs close to benchmark
  • The BRK tilt suggests a deliberate (but small) quality/value accent on top of index exposure
  • They're not trying to generate alpha through stock selection — they're providing institutional-quality market exposure with minor tilts

About how to analyze similar filings

When a filing is 95% index-like, focus your analysis on the 5% that deviates. BRK at #12 is that 5% for BNY Mellon.


Originally published at 13F Insight

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