The U.S. Securities and Exchange Commission (“SEC”) recently adopted a new rule, Rule 13h-1 (“Rule”) under the Securities Exchange Act of 1934, as amended (“Exchange Act”),1 that requires persons that fall within the definition of a “large trader” based on their volume of transactions in NMS securities2 (“Large Trader”) to: (i) periodically file new Form 13H with the SEC disclosing information regarding their organization and its use of broker-dealers; (ii) obtain a unique “Large Trader Identifier” (or “LTID”) that the Large Trader must provide to registered broker-dealers through which transactions are executed; and (iii) respond to ad hoc informa-tion requests. Broker-dealers that carry accounts for, or effect transactions on behalf of, Large Traders will be required to maintain and, when requested by the SEC, be able to produce certain records of transactions by Large Traders on the next morning after the date the transactions were effected. The Rule is designed to allow the SEC both to conduct market surveillance and analyze potential securities law violations more efficiently.

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