In Release No. 34-64976 (the “Release”), the Securities and Exchange Commission (“SEC”) adopted new Rule 13h-1 and Form 13H under Section 13(h) of the Securities Exchange Act of 1934 (“Exchange Act”). Section 13(h) authorizes the SEC to establish a large trader reporting system.

The SEC has stated that it believes that large trader reporting requirements will provide the SEC with a valuable source of useful data that will greatly enhance the SEC’s ability to identify large market participants, and collect and analyze information on their trading activity. Prior to the Release, the SEC collected transaction data from registered broker-dealers through the Electronic Blue Sheets (“EBS”) system. Rule 17a-25, adopted in 2001, enhanced the EBS system and improved the SEC’s ability to obtain electronic transaction records.