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On October 13, 2023, the SEC adopted new Rule 13f-2 under the Securities Exchange Act of 1934 that will require institutional investment managers (“Managers”) that meet or exceed a specific threshold to report monthly, using new Form SHO, specified short position data and short activity data for equity securities to the Commission. Managers have until January 2, 2025 to comply with the requirements under Rule 13f-2, with the Commission publishing aggregated data a few months thereafter.

Whether it be the extraterritorial scope, the broad definition of “equity securities” or the potential for reverse engineering of short position data, there is plenty for Managers to consider in the meantime.  However, one thing is for certain: Rule 13f-2 will create new, significant costs and risks for both U.S. Managers and even foreign Managers with limited jurisdictional ties to the U.S.

Please join AIMA and Schulte Roth & Zabel for a discussion into Rule 13f-2, its practical implications and what Managers can do to prepare for next January’s compliance deadline.

Speakers:

Adriana Schwartz, Partner, Schulte Roth & Zabel

Derek Lacarrubba, Special Counsel, Schulte Roth & Zabel

Daniel Austin, Head of US Markets Policy and Regulation, AIMA

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