SEC Clarifies Short Sale Restrictions and Related Disclosure Requirements


In an effort to address continuing market volatility, the SEC issued a series of emergency orders to limit short

sales and require reporting of short positions. Please see our September 22, 2008 Client Alert.1 Given the speed

with which these emergency orders were issued and the questions raised regarding their implementation, the SEC

has since issued additional interpretive guidance to assist in the compliance with these new regulatory


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