NAPFM, AIMA and MFA Challenge SEC Securities Lending and Short Position Reporting Rules

Published: 12 December 2023

Pursuant to 5 U.S.C. §§ 702-704, 706, 15 U.S.C. § 78y, and Federal Rule of Appellate Procedure 15(a), the National Association of Private Fund Managers, Managed Funds Association, and Alternative Investment Management Association hereby petition this Court for review of (i) the order of the U.S. Securities and Exchange Commission issuing a final rule in Reporting of Securities Loans, Release No. 34-98737, a copy of which is attached as Exhibit A (the Securities Loan Reporting Rule); and (ii) the order of the U.S. Securities and Exchange Commission issuing a final rule in Short  -2-  Position and Short Activity Reporting by Institutional Investment Managers, Release No. 34-98738, a copy of which is attached as Exhibit B (the Short Position Reporting Rule), both of which were entered by the Commission on October 13, 2023.  

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