Proposed SEC Changes FAQ

Overview

In response to the growing inquiries from our clients, we are excited to share key updates on our latest initiatives. This article provides an overview of the forthcoming changes and enhancements. The FAQ focuses on how FundApps is responding to the proposed changes to the updated beneficial ownership reporting requirements and the new short-selling rule.

Beneficial Ownership Updates

We released an updated rule version for 13D on 22 January 2024 to reflect the deadline changes that went into effect on 5 February 2024. 

Please check back for additional updates regarding our analysis and implementation of the 13G changes, including the later deadline for EDGAR submissions.

13f-2 Disclosures & Form SHO

Our Regulatory team is staying on top of the latest developments with this new regulation. Based on the information available at this stage, below is our current approach (subject to change).

Will I have to monitor?

We've created this guide to help you determine if you are subject to section 13f-2’s regulatory
reporting obligation. 

How will FundApps help clients stay compliant with the new requirements?

We plan to create end-of-month alerts for US 13f-2 disclosure requirements, similar to our other shareholding disclosure results. This will cover monitoring under the new requirements.

Will clients have to provide new files?

No, a significant aspect of our strategy involves utilizing clients' end-of-day positions and portfolio files.

Will clients have to provide additional data?

While aosphere’s United States memo doesn’t include 13f-2 coverage (yet), our team is forging ahead, using the published rule as guidance, and speaking directly with the SEC as needed.

Linked here is a list of properties we expect to use for 13f-2. Please note that this is provisional, and we welcome and encourage client comments

When will we know if the data requirements will change?

Pending information from aosphere, we hope to inform our clients by Q2.

Will FundApps automate form SHO?

We plan to support the generation of form SHO. At this stage, we anticipate that transaction data from clients will not be necessary for populating Form SHO.

Exploring Support for EDGAR in Filing Manager

In an effort to further assist our clients, we are also exploring support options for EDGAR submissions through our Filing Manager service. As part of this initiative, we are interested in shadowing clients as they undertake their Q4 2023 13f-1 filings. Understanding your specific needs and challenges is an important step, so if interested, please contact our FundApps Support team.

Stay tuned for more! 

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