Abstract
PurposeThe purpose of this paper is to provide frequently asked questions and answers in connection with the large trader reporting system.Design/methodology/approachThe paper explains the large trader rule and filing requirements, including the application of the rule to non‐US entities; definitions, including Securities and Exchange Commission's (SEC's) definition of a “large trader”, a “NMS security”, and “person” for purposes of the rule; filing requirements; and the likely impact of broker‐dealers.FindingsCertain broker‐dealers and entities that meet a trading threshold of aggregate transactions in NMS securities that equal or exceed two million shares or $20m during any calendar day, or 20 million shares or $200m during any calendar month, must file a Form 13H with the SEC.Practical implicationsThe rule requires attention to an entity's trading levels, and requires making a filing with the SEC upon meeting certain activity levels.Originality/valueThe paper presents practical guidance from experienced financial services lawyers and compliance officers.
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