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FIF Short Sale Implementation Working Group

The purpose of this working group is to discuss areas/resources impacted, implementation issues and areas requiring clarification from SEC, SROs and other SIPs concerning the SEC Short Sale rule.

Short Sale Implementation Portal

FIF Short Sale Implementation Relevant Links Portal (FIF Member Only)
FIF maintains a list of hyperlinks to SIP, exchange and regulatory websites related to the implementation of the new short sale rules.

Meeting Materials/Minutes

April 28, 2010 - FIF Short Sale Implementation WG Meeting with the SEC Posted [2010-05-03]
FIF Member list of questions for the SEC on Short Sale implementation
April 06, 2010 - FIF Member Feedback on Open Issues Surrounding Short Sale Implementation Posted [2010-04-06]
Updated document containing meeting agenda and FIF member questions on areas requiring clarification from the SEC, SROs and CTA/UTP
March 23, 2010 - FIF Member Feedback on Open Issues Surrounding Short Sale Implementation Posted [2010-03-23]
Initial document containing meeting agenda and FIF member questions on areas requiring clarification from the SEC, SROs and CTA/UTP

Current Documents

SEC, Listing Exchanges and FINRA Answers to FIF Member Questions Posted [2010-07-02]
Additional SEC, Listing Markets and FINRA feedback on FIF Member Questions on Short Sale Implementation
SEC Email Response to Short Sale Exemption Request Posted [2010-07-02]
Email outlining SEC's position on FIF's request for Short Sale Exemption
SEC and FINRA Answers to FIF Member Questions Posted [2010-06-01]
SEC and FINRA feedback on FIF Member Questions on Short Sale Implementation
Excerpt - Text of Amendments to Regulation SHO Posted [2010-03-23]
Document containing text of amendments to Regulation SHO
SEC Amendments to Regulation SHO Posted [2010-03-22]
Complete text of SEC Amendments
FIF Term Sheet on SEC Short Sale FAQ 2.4 and 2.5 Posted [2010-02-08]
FIF Request for Interpretive Relief With Respect to the Regulation SHO Aggregation and Marking Requirements
FIF Term Sheet on SEC Short Sale FAQ 2.4 and 2.5 Posted [2010-02-08]
FIF Request for Interpretive Relief With Respect to the Regulation SHO Aggregation and Marking Requirements
SEC Amendments to Short Sale - Excerpt Posted [2009-04-28]
Excerpts from the 273 page filing on Amendments to the Short Sale Rule published by the SEC on April 10, 2009.

Comment Letters

June 23, 2011 - FIF Comment Letter to the SEC on Short Sale Reporting Study Required by DoddFrank Posted [2011-06-23]
FIF Comment Letter to the SEC regarding real-time position reporting and transaction reporting on Short Sale Reporting Study required by Dodd-Frank Act Section 417(a)(2)
Sep 17, 2010 - FIF Comment Letter to the SEC on New OATS Route Report Requirements Posted [2010-09-24]
FIF Comment Letter to the SEC on Addition of Routed Price and Short Sale Exempt Identifier to OATS Route Reports
Jul 26, 2010 - FIF Comment Letter to the SEC on Short Sale Exemptive Relief Posted [2010-07-26]
FIF Letter to the SEC requesting exemptive relief for the facilitation of Customer or Dealer Sell Short Order as Riskless Principal when Firm's position is Net Long
Sep 23, 2009 - FIF Comment Letter II to the SEC on Short Sale Posted [2009-09-23]
FIF Letter to the SEC offering feedback on proposed Short Sale Amendments
June 19, 2009 - FIF Letter to the SEC on Short Sale Posted [2009-06-19]
FIF Letter to the SEC commenting on proposed Short Sale Amendments

Archive Documents

SEC Amendments to Short Sale - Excerpt Posted [2009-04-28]
Excerpts from the 273 page filing on Amendments to the Short Sale Rule published by the SEC on April 10, 2009.


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