Form SHO Filing Service

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In October 2023, the Securities and Exchange Commission (SEC) introduced Rule 13f-2 and Form SHO, setting a new standard for transparency in short-selling activities by institutional investment managers. The regulation mandates monthly disclosures of certain short positions to enhance market oversight and prevent manipulation.

Form SHO Filing Agent Service

• Streamline the process of compiling an EDGAR Form SHO report.

• Don’t waste time learning new software – complete one easy template and leave the rest to us.

• The ACN Solutions for Form SHO:

  • YOU - Send us your short position information using our Excel template

  • ACN – Analyzes your data and prepares a proof. We will:

    • Determine which short positions are subject to Threshold A or Threshold B

    • Identify which short positions are reportable under the relevant threshold

    • Calculate the daily net change in short positions

    • Populate the identifying information for each information table

  • YOU - Review & approve the Form SHO proof

  • ACN – Performs a double-check of your Form SHO report before submitting to EDGAR

Form SHO Key Reporting Requirements:

Institutional investment managers must submit Form SHO via the EDGAR system by the 14th of each month, provided their short positions meet or exceed specific thresholds. The reporting requirements for Form SHO differ based on two key thresholds:

1. Threshold A: Reporting for U.S.-Listed Public Companies (Reporting Company Issuers)
   For equity securities registered under Section 12 of the Securities Exchange Act (i.e., public companies) or for issuers required to report under Section 15(d). Threshold A will require reporting by Managers that have, for each equity security of a reporting company issuer, either

• a monthly average gross short position at the close of regular trading hours in the equity security with a U.S. dollar value of $10 million or more; or

• a monthly average gross short position at the close of regular trading hours as a percentage of shares outstanding in the equity security of 2.5 percent or more

2. Threshold B: Reporting for Non-Reporting Companies
   For equity securities of non-reporting issuers. Threshold B will require reporting by Managers that have, for each equity security of a non-reporting company issuer, a gross short position in the equity security with a U.S. dollar value of $500,000 or more at the close of regular trading hours on any settlement date during the calendar month

Helpful Resources:

• ACN Form SHO FAQ

• SEC Rule 13f-2 Press Release

• SEC Rule 13f-2 Fact Sheet

• SEC Form SHO Final Rule / 13f-2 Final Rule