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SEC Extends Form SH Short Sale Reporting Until Aug. 1, 2009, and Modifies Timing and Scope of Disclosure

October 16, 2008


On Oct. 15, 2008, the Securities and Exchange Commission (the “SEC” or the “Commission”) issued a release (the “Release”) adopting an interim final temporary rule (the “Temporary Rule”) regarding the reporting of short sales and short positions on Form SH. The Temporary Rule extends the weekly reporting requirements of Form SH until Aug. 1, 2009, and will apply to all institutional managers required to file a Form 13F for the calendar quarter. In the Release, the SEC seeks comments with respect to many aspects of the short sale reporting and, more generally, with respect to the utility of such reporting.