Overview

The Securities and Exchange Commission adopted the “large trader” reporting rule on July 26, 2011. New Rule 13h-1 will require all “large traders” to register with the SEC on Form 13H and obtain a unique large trader identification number, which the large trader must then provide to its registered broker-dealers. Broker-dealers must maintain the records specified in Rule 13h-1 for all large traders and provide large trader transaction information to the SEC upon request. Broker-dealers will provide the required information to the SEC through the Electronic Blue Sheets system currently used by broker-dealers for reporting trade information.

As described in more detail below, large traders are defined as traders with aggregate transactions in NMS securities (listed options and equities) that are equal to or greater than (i) 2 million shares or shares with a fair market value of $20 million per calendar day or (ii) 20 million shares or shares with a fair market value of $200 million per calendar month.