On 7 July 2025, FIF submitted another letter (in addition to prior nine letters) to the SEC relating to the implementation of Short Selling Rule 13f-2 and associated Form SHO.

• Reminded SEC time is short to revise and clearly define the short selling reporting requirements for Form SHO, if the Commission plans to maintain the new February 2026 reporting deadline.
• Urge SEC to stay implementation of current Rule 13f-2 and propose amendments to Short Selling Disclosure Rule 13f-2 previously recommended by FIF members to address various inefficiencies.