SEC Further Extends Form SHO Compliance Date to 2028

On December 3, 2025, the Securities and Exchange Commission (the “SEC”) further extended the date for compliance with Rule 13f-2 under the Securities Exchange Act of 1934 (“Exchange Act”) and the related reporting on Form SHO to January 2, 2028. As a result of this extension, the first Form SHO filing deadline will be February 14, 2028.  The original compliance date (January 2, 2025) was first extended to January 2, 2026 by way of a temporary exemption issued by the SEC on February 7, 2025. Under Rule 13f-2, an “institutional investment manager”1 that meets or exceeds the applicable reporting threshold set forth in Rule 13f-2 in respect of an equity security2 during a month is required to file Form SHO with the SEC within 14 calendar days after the end of that month to report specified gross short position and activity data for that equity security. Seward & Kissel previously published a memorandum (available at the link below) that summarizes the new Rule 13f-2 requirements. CLICK HERE TO READ THE FULL MEMORANDUM Please contact an attorney in the Investment Management Group at Seward & Kissel LLP if you have any questions regarding this extension or on Form SHO in general.