On July 26, 2011 the U.S. Securities and Exchange Commission (the “SEC”) adopted Rule 13h-1, which implements registration and reporting requirements for large traders.

Rule 13h-1 is intended to allow the SEC to effectively monitor the trading activity of market participants who conduct substantial trades whether in terms of volume or dollar amount. Under Rule 13h-1, large traders must self-identify and register with the SEC by filing Form 13H through EDGAR. Subsequently, broker-dealers who execute trades for these large traders must comply with recordkeeping, reporting and monitoring requirements.