Should institutional investment managers aggregate short sales across client accounts, strategies, and funds?
Under Column 4 of Form SH (“Number of Securities Sold Short (Day)”), the investment manager should report the aggregate gross short sales across all accounts in each Form SH Security effected that day. Question 17: If an institutional investment manager has one client account that has a short position in a Form SH Security and a second client account that has a long position in the same Form SH Security, how should these positions be reported on Form SH? Answer: Form SH does not require disclosure of long sales. In addition, long sales should not be netted against short sales either across client accounts or within a client account for purposes of reporting on Form SH. However, if a purchase or other transaction closes out an open short sale that was effected after the effective date of the Order, there will be a decrement (or diminution) of the open short position for that account. For start of day and end of day short position reporting, the manager must determine the total open shor
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