13f-2 US Short-Selling Service

Overview

To address the SEC’s new US short reporting requirements, FundApps has released a 13f-2 service to ensure our clients are covered when the new regulation comes into effect in January 2025.

Using the same datasets already being sent to FundApps daily, our rule engine will calculate disclosure requirements based on the monthly average percentage and nominal values or the daily nominal values for non-reporting company issuers.

13f-2 Page Layout

The new 13f-2 follows the workflow logic every FundApps user is already familiar with while introducing new design solutions to address the specific requirements of the US short-selling regulation. The page is divided into 3 main sections.

Result Tables

The page includes two result tables. The table on the left provides the user with an overview of all asset classes being monitored by the 13f-2 rules, including both reporting and non-reporting company issuers. Selecting an asset class on the left will populate a table on the right-hand side, which provides a detailed view of how the respective 13f-2 position has changed over the course of the month.

For detailed information about the different 13f-2 results types, follow the link here

Exposure Timeline

The Exposure Timeline gives clients a visual representation of the change in position of the asset class selected previously in the Results Table. Users can toggle between the USD Market Value and the Class Shares Percentage graphs for reporting company issuers and are shown the USD Market Value for non-reporting issuers. The thresholds can be highlighted in the graph as well and for reporting company issuers, the averages are displayed.

Asset Details

Once a user selects a NAV Date either on the result table on the right-hand side or on the exposure timeline, the asset details are displayed at the bottom of the page. This view is similar to the asset details view users are already familiar with from the Shareholding Disclosure and Sensitive Industries services.

FAQs

Q: Will FundApps cover form SHO?
A: Yes, FundApps will enable users to generate the form SHO within the platform. At this point, we are waiting for the SEC to release the XML schema, and we will keep clients posted on any updates regarding the form SHO.

Q: How does FundApps distinguish between reporting and non-reporting company issuers?
A: FundApps has developed an issuer-level property, IsReportingCompanyUS. This is an optional property and will serve as an additional check in conjunction with MarketsListedIn, allowing you to have direct control over the threshold an issuer falls in scope of, leading to more accurate results. If set to true, the issuer will be treated as a reporting company issuer and will fall in the scope of Threshold A.

FundApps is aware that sourcing the required information to populate IsReportingCompanyUS may be difficult. As such, we’re offering a solution that will enrich this data using information from the SEC’s EDGAR database for issuers filing 10K, 20F, and 40F reports. This dataset will identify which threshold the issuer is in scope for, either Threshold A or Threshold B. If you are interested in learning more about this, please reach out to your account manager.

Q: How does FundApps satisfy the requirement to calculate exposure as per the settlement day?
A: FundApps allows clients to provide a property named QuantitySettle, which represents the number of shares held on the settlement date. If this property is included in the file, the engine will use this settlement quantity to calculate the 13f-2 short exposure. However, during our market analysis some clients have indicated they cannot reliably provide quantities as of the settlement date. Therefore, we decided to include logic in our rule set to default to using the "normal" Quantity property to calculate the 13f-2 results if QuantitySettle is not provided.

Q: Will FundApps require transaction data for the rule calculation or form SHO?
A: No, FundApps does not require transaction data in addition to the daily positions file already provided to the platform by our clients. The information needed by the monthly average calculation for reporting company issuers, the nominal value calculation for non-reporting company issuers as well as the daily net-short change, which will need to be populated in form SHO, can all be derived from the daily position file.

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