2024: All things SEC
What's new, what's changed, and what's important?
The SEC headliner grabbers for this year are the 13f-2 short selling rule and Form SHO. It's all about bringing transparency to short reporting as required by the Dodd-Frank Act. The compliance date is 2 January 2025 and there's a lot to unpack, make judgement calls on and get ready for. Institutional investment managers will need to be clear when reporting obligations are triggered, make sure they meet the data requirements (including any new data points), be able to file based on average end-of-day positions over an entire month, be clear which securities are in scope and which aren't - even without an official list - and report on Form SHO. EDGAR also comes into play.
Compliance with most of the amendments for the Modernisation of Beneficial Ownership was on 5 February 2024. But, hold on, compliance with the accelerated Schedule 13G filing deadlines is on 30 September 2024 (and don't forget the new inclusion of derivatives securities) and the need for structured machine-readable data requirements for 13D and 13G is on 18 December 2024.
So there's a lot to learn, debate and get ready for.
The change and the challenges
What's going to be difficult for compliance officers? The implementation of US short-selling rules and Form SHO is pushing financial institutions to embrace automation. The SEC's message is clear: it's time for firms to not just understand and adjust to these changes, but to proactively reshape their compliance strategies.
The new US short selling rules: what’s going to be difficult for compliance officers?
New US short selling rules bring challenges for compliance officers: expanded reporting, XML filings, issuer thresholds, and daily position tracking.
Why you should care about the latest SEC disclosure regulations
The latest SEC disclosure regulations have brought significant changes to beneficial ownership reporting and short sale disclosure rules.
SEC: Changes to Private Fund Reporting for US Investment Advisers
On 10 August 2022, the SEC voted 3-2 to propose amendments to Form PF (‘the Form’).
SEC Proposes Changes to Section 13 and Short Sale Requirements
Dave Polonsky gives a run through of the new, proposed changes to beneficial ownership and short-selling reporting by the SEC.
SPACs and what you need to disclose under Section 13 of the SEA
Special Purpose Acquisition Companies (SPACs) are on the rise, but SPAC data providers are not about to provide necessary SPAC reporting under Section 13 of the Securities ...
SEC Proposes Amendments to 13G and 13D Beneficial Ownership Reporting
An overview of the proposed changes to Section 13G and Section 13D by the SEC, the first of their kind in more than 40 years.