What is the “time” of the largest intraday short position?
Firms typically track intraday short positions in a Form SH Security for risk management purposes, based upon communications received from execution venues regarding executed orders. The time of the largest intraday short position is the time when the largest intraday short position in that Form SH Security is reached, based on the time of the last fill of the short sales. Consistent with Rule 12b-21 under the Exchange Act, information that is required need be given only insofar as it is known or reasonably available to the institutional investment manager. If any required information is unknown and not reasonably available to the institutional investment manager, either because the obtaining thereof could involve unreasonable effort or expense, or because it rests peculiarly within the knowledge of another person not affiliated with the institutional investment manager, the information may be omitted, subject to the following conditions: (a) the institutional investment manager shall
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