MFA submitted a letter, together with AIMA, requesting that the staff of the Division of Trading and Markets of the SEC grant no-action relief if our members do not comply with the reporting requirements set forth in new Rule 13f-2 and related Form SHO until July 1, 2025. MFA submitted the letter in draft form and for discussion purposes only.
Despite significant efforts, members are very concerned about their ability to file their first Form SHO report by February 14, 2025, without the report containing incomplete or incorrect information. The letter identifies both technical issues and uncertainty regarding how (or whether) to report certain data, given the lack of clear guidance from the Commission on certain issues. It also highlights the volume of submissions and the serious operational issues raised by filing Form SHO through EDGAR and its effect on the integrity of the EDGAR system.
