Short Position and Short Activity Reporting by Institutional Investment Managers (Joint Trades)

SIFMA, SIFMA AMG, the Investment Company Institute (ICI), the Insured Retirement Institute (IRI), the FIA Principal Traders Group (FIA PTG), and the Investment Adviser Association (IAA) provided comments on behalf of their respective members relating to the implementation of Rule 13f-2 and the associated Form SHO adopted by the Securities and Exchange Commission (SEC) on October 13, 2023 to request an 18-month extension of the compliance date for the rule, which is currently January 2, 2025.