Recent SEC Actions Regarding Short Sales
In response to recent stock market volatility, the Securities and Exchange Commission has adopted sweeping temporary orders with respect to short sales. As described in the attached memorandum, institutional investment managers that filed a Form 13F for the quarter ended June 30, 2008 must report short sales effected on or after September 22, 2008 on a new Form SH. In addition, subject to certain exceptions, short sales in publicly traded shares of certain financial firms are prohibited. We note that the securities industry is engaged in continuing discussions with the SEC regarding the scope and implementation of these short sale regulations.