Based on U.S. Department of Labor Form 5500 filings (plan years 2022–2024), 2 U.S. retirement plans report holding SAP ADR Stock Fund in their Schedule of Assets, totaling $122.5M in parsed positions. Matched on the normalized security name across each plan’s latest filing and ranked by position size.
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| # | Sponsor / Plan | Location | Participants | Plan assets (EOY) | Position |
|---|---|---|---|---|---|
| 1 | SAP AMERICA, INC. SAP AMERICA, INC. 401(K) PLAN | NEWTOWN SQUARE PA | 16,587 | $8.1B | $121.7M |
| 2 | QUALTRICS LLC QUALTRICS 401(K) PLAN | PROVO UT | 2,688 | $445.8M | $868K |
