The SEC Short Sale Rule: Addressing the Ambiguity and Answering Members’ Questions


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We are now only several months away from the January 2, 2025 compliance deadline for the SEC’s new Exchange Act rule 13f-2 that requires institutional investment managers to report certain short sale data.  Although we are optimistic that our pending challenge against rule 13f-2 (and the securities lending rule) will be successful, the compliance deadline will likely arrive before there is a final decision from the Fifth Circuit Court of Appeals.  In the meantime, we’ve begun receiving and reviewing a number of questions from managers about some of the extensive ambiguity that is in the final rule and how managers should interpret/implement some of these outstanding issues.

This webinar, with our partners at Schulte Roth & Zabel, will be to discuss many of the outstanding questions/issues members may be facing as they build toward compliance.  Ahead of the webinar, we’re putting out a call for questions that we’ll share with Schulte ahead of the event so that they can be best prepared to react and respond.  Please send Daniel Austin any questions/issues your firms may be working through by Friday, July 12 so that Schulte can have sufficient time to consider them ahead of the webinar.

After the webinar, we plan to publish a working document that will be accessible on the AIMA website that will include questions and answers from the webinar and future questions we may receive.


  • Adriana Schwartz, Partner, Schulte Roth & Zabel
  • Derek Lacarrubba, Special Counsel, Schulte Roth & Zabel
  • Daniel Austin, Head of U.S. Markets Policy and Regulation, AIMA

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