Eminence submitted a comment letter to the Securities Exchange Commission (SEC) on the proposed rules regarding short position and short activity reporting. Eminence recommends that the SEC leverage FIRNA’s existing framework for aggregate short sale data reporting, rather than implementing the framework in the proposed rules.
In the letter, Eminence notes it support for the publication of high-quality, aggregated, anonymized short position data. Additionally, the letter raises concerns about the proposed rules, specifically the introduction of a complex and costly reporting framework. Eminence stresses that this framework would impose burdens on alternative asset managers. Also, the letter argues that the economic analysis underestimates the actual cost of implementing the proposed rules. Eminence strongly emphasizes that leveraging the FIRNA framework would enhance the usefulness of the data.
