Seward & Kissel briefing on the SEC’s gross short position rules
Seward & Kissel’s briefing on Rule 13f-2 which would require monthly publications of specified gross short positions and activity data above certain thresholds.
What’s new?
On 8 November 2023, Seward & Kissel, our alliance firm for hedge fund and asset management work, published a client briefing (the Briefing) on Rule 13f-2 (the New Rule) adopted by the SEC on 13 October 2023.
Under the New Rule, an investment manager that meets or exceeds any of the reporting thresholds, will be required to report specified gross short position and activity data for equity securities. Such reports will be required monthly and made on Form SHO.
The New Rule will become effective on 2 January 2024. The compliance date for the New Rule will be on 2 January 2025.
Seward & Kissel’s Summary
The Briefing looks in turn at:
- Filing requirements and time limits
- Reporting Company Issuer Thresholds
- Non-Reporting Company Issuer Thresholds and
- An obligation to amend filing information in case of errors or inaccuracies
For more information on the New Rule, contact an attorney at Seward & Kissel (see the list at the foot of the Briefing) or Devarshi Saksena, Lucian Firth or Sarah Crabb.
