The date for complying with new Rule 13f-2 and filing Form SHO has been extended by one year. The first filings by covered institutional investment managers will now be due February 17, 2026, rather than February 14, 2025.
On February 7, 2025, the US Securities and Exchange Commission (SEC) announced a temporary exemption from compliance with Rule 13f-2 under the Securities Exchange Act of 1934, which requires certain institutional investment managers to file new Form SHO to report short positions that exceed specified thresholds in a calendar month.
Prior to the temporary relief, the first Form SHO filings (relating to short positions held during January 2025) would have been due by February 14, 2025. As a result of the temporary relief, the first filings (relating to short positions held during January 2026) will be due by February 17, 2026.
In announcing the temporary exemption, the SEC stated “This exemption will provide industry participants sufficient time to work with Commission staff to address any outstanding operational and compliance questions. This exemption will also provide filers sufficient time to complete implementation of system builds and testing.”
For more information about Rule 13f-2 and Form SHO, please see our earlier LawFlashes.
Reminder: SEC’s New Short Sale Reporting Filings Due February 2025
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