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1. agenda agenda Public

   Project issues

2. SHO-XML-technical-specifications.md SHO-XML-technical-specifications.md

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   # About Form-SHO Data Reporting

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   Exchange Act § 13(f)(2), added under Dodd-Frank § 929X, requires the Commission to prescribe rules to make certain short-sale-related data publicly available. Rule 13f-2 [was passed](https://www.sec.gov/rules-regulations/2023/10/s7-08-22) on 13 Oct 2023, originally requiring the transparent reporting of these shorting activities. Money managers were supposed to use the 2024 calendar year to prepare for the submission of this crucial data. The Commission released the reporting standards a couple of weeks before the statutory effect date on 2 Jan 2025, with filings due a month and a half thereafter.

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   On 18 Nov 2024, the Commission released a draft XBRL filing guide with details for reporting short-sale data from institutional investment managers. Industry participants since claim these data conversion turnaround times were impossible to comply with, and successfully sought a reporting delay from the Commission, presently amounting to a full additional year. However, we posit that these managers had months to prepare the minor and complementary[^comps] reporting standards, based on the final equivalent submission rules released on 16 Dec 2024. Hence I present a comparison of the drafting materials and finished implementation released from staff in PDF documentation.