Short selling reforms are a key part of NIRI's advocacy agenda. In October 2015, NIRI joined with the NYSE Group in a rulemaking petition that asks the SEC to require 13(f) institutions to publicly report their short positions. In December 2015, Nasdaq submitted a similar rulemaking petition, which has been endorsed by the Biotechnology Innovation Organization, a trade association that represents biotech companies.   

NIRI encourages members to ask their companies (or clients) to write comment letters to the SEC that support this much-needed reform to improve equity ownership transparency. Comment letter templates and letters from a growing list of companies can be found below.   


NIRI Briefing Paper, The Case for Improved Disclosure of Short Positions (May 2016)

Edward Knight, General Counsel, Nasdaq, "The Long and Short of Unfair Trade Rules," The Hill, January 18, 2018

MiMedx Group, "Petition for Rulemaking to Require Disclosure of Short Positions," November 1, 2017.

NIRI, IR Update, "The Long and the Short of It: There Is a Growing Consensus Among Companies That the SEC Should Mandate the Public Disclosure of Short Positions" (June-July 2016)

NYSE-NIRI Rulemaking Petition to the SEC on Short-Position Disclosure (October 2015)

Nasdaq, Petition for Rulemaking to Require Disclosure of Short Positions in Parity with Required Disclosure of Long Positions (December 2015)

Biotechnology Innovation Organization, Comment Letter to the SEC: Request to Require Disclosure of Short Positions in Parity With Required Disclosure of Long Positions (March 2016)


Comment Letter Templates

Sample Comment Letter for NYSE Companies

Sample Comment Letter for Nasdaq Companies

Comment Letters Submitted by Companies With NIRI Members

Cardinal Health

Freeport-McMoRan Inc. 

Herbalife Ltd.

BOK Financial Corp. 

Primoris Services Corp.

Revance Therapeutics, Inc.

Tyler Technologies

Approach Resources

EnerNOC Inc.