December 2025

United States Short Selling

Information

On December 3, 2025, the SEC granted additional temporary relief, extending the exemption from reporting on Form SHO to January 2, 2028. Instead of the previously set deadline of first filing in February 2026, the compliance date for first filing Form SHO has been extended by a full two years to February 2028.

Our Thoughts

To navigate a fluid regulatory landscape, managers must remain vigilant of new requirements like Rule 13f-2 while proactively using available time to validate data and address operational gaps. By identifying these challenges early, firms can develop a clear roadmap to implement the necessary policies and systems, ensuring they are fully prepared to respond once new rules take effect.

For added depth in perspective, please refer to our Regulatory Insights.

The above content is purely for information and does not purport to offer legal or professional counsel.