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Alerts
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Update on SEC Form SH Filing Requirements
October 23, 2008
The SEC staff yesterday provided informal guidance with respect to the reporting of short sales and positions on Form SH pursuant to Temporary Rule 10a-3T (the “Temporary Rule”). Following release of the Temporary Rule on Oct. 15, 2008, questions were raised as to whether the Temporary Rule requires reporting of all short positions in section 13(f) securities during the reporting period, or just of short sales executed in section 13(f) securities during the reporting period. The Emergency Order issued on Sept. 18, 2008, instituting the Form SH filing requirement, only required filers to report with respect to section 13(f) securities they shorted during the reporting period (subject to a de minimis exception).
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