CommEnt Letter

SEC Proposed Rule 13f-2

13f-2 Comment
Letter Template

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The SEC has proposed a new rule, 13f-2, to provide disclosure and transparency around short positions being held by investment managers. They recently re-opened the comment file for this rule for 2 weeks. We The Investors will be filing a comment letter on this rule, and encourage our supporters to do so as well.

The SEC has also proposed a new rule for transparency in securities lending (10c-1), and our partners at Prodigium Pictures have put together an overview for you.

How To File a Comment Letter

If you are interested in filing a comment letter, the simplest and safest way is to do so by email. If you would like to write your own comment letter, we have some guidance and information for you. However, there is not much time for this rule filing - they have only re-opened the comment file for 2 weeks. Therefore, we would encourage you to take the letter that we have filed, make sure that you agree with its content, feel free to customize it if you'd like, and then sign and file it. We have linked to two different formats on the right.

When signing a comment letter, you can do so electronically (type your name and position/title at the bottom) or print, sign and scan it.

Please follow these steps to file the comment letter:

  1. The subject line must include the File Number. For this proposal, you should use this subject: "Comment Letter for File Number S7-08-22 Short Position and Short Activity Reporting by Institutional Investment Managers"
  2. Attach your comment letter, preferably as a PDF (alternatives include Word or Text docs).
  3. Send the email to
  4. Share this on social media! Let everyone know that you've gotten involved in the process, that you've put the effort in to make yourself heard, and encourage them to do the same. Use the hashtag #WeTheInvestors.