Disclosure of Short Sales & Short Positions by Institutional Investment Managers

SIFMA provides comments to the Securities and Exchange Commission (SEC) on the disclosure of short sales and short positions by institutional investment managers (Interim Final Temporary Rule 10a-3T and Temporary Form SH under the Securities Exchange Act of 1934) , Release No. 34-58785; File No. S7-31-08. The interim final temporary rule would require certain institutional investment managers to file information concerning their short sales and short positions in section 13(f) securities.  SIFMA shares its concerns relating to the scope of managers covered by the Rule, alternative approaches to reporting positions and activities, which short sales and short positions are required to be reported,  exceptions to reporting requirements, transition and expiration dates for Rule 10a-3T, and comments on Form SH.