On 8 November 2024, FIF submitted letter requesting extension for implementation of the 13f-2 short selling rule.

• Requests 6-month extension of implementation date, with such 6-month period to run from the date that the Commission publishes written FAQs in response to questions.
• Follows 5 November 2024 FIF submission of comment letter on draft technical specification.
• Members concerned that a manager could have more than 100 records to report for Tables 1 and 2, request increased to unlimited or total number of potential thresholds.
• Asks Commission to communicate when managers can submit test files to EDGAR.
• FIF members requests that Commission provide data dictionary for each data element.
• Interpret that short selling positions in convertible bonds are not taken into account for Form SHO reporting unless actually converted, request that Commission confirms that position.
• Also requests clarification for scenario where issuer is required to file reports pursuant to Section 15(d) based on issuer having filed registration statement for security class.
• The members also request confirmation that manager can submits Form SHO report for calendar month at any time prior to close of EDGAR system on due date for report.