On October 13, 2023, the U.S. Securities and Exchange Commission (the “SEC”) adopted final rules requiring the reporting and disclosure of short sale trade data information. New Rule 13f-2 implements new obligations on certain institutional investment managers (“Managers”) to report short position and activity data for certain equity securities on new Form SHO. The SEC also amended the national market system plan governing the consolidated audit trail (“CAT NMS Plan”) relating to disclosure of short sales made under the bona fide marketing exception.