STA Comment Letter on Short Position and Short Activity Reporting

The Security Traders Association (“STA”) appreciates the opportunity to provide
comments in response to the aforementioned proposal (the “Proposal”)2 published by
the U.S. Securities and Exchange Commission (“SEC” or “Commission”). STA is an
organization comprised of individuals who are involved in the trading of financial
securities in the U.S and Canada. Our members are employed at retail brokerage firms,
agency only broker-dealers, asset owners and managers, market makers, liquidity
providers and exchanges.

The Proposal seeks to introduce new Rule 13f-2 under the Securities Exchange Act of
1934 (Exchange Act) and new proposed Form SHO, which would require institutional
investment managers (as such term is defined under Section 13(f)(6)(A) of the Exchange
Act (Institutional Investment Managers)), to report to the SEC extensive information on
certain “large” short positions and short sale and other transactions on a monthly basis.
The SEC would then use this data to make publicly available by issuer aggregate data
about short positions and short sale activity.

Read the comment letter here.