The Investment Company Institute1 (ICI) is writing to request that the staff of the Division of Trading and Markets (“Staff”) confirm that it will not recommend that the Securities and Exchange Commission (SEC or “Commission”) take enforcement action under the Securities Exchange Act of 1934 (“Exchange Act”) against institutional investment managers for failure to file Form SHO reports as required by Rule 13f-22 under the Exchange Act until the Staff has provided additional interpretive guidance on compliance with the rule. The need for this no-action relief is urgent because of the impending February 14, 2025, deadline to file the first Form SHO reports.
The full comment letter is available here.