FORM SH
SEC Emergency Order - Short Sales and Short Positions

On October 15, 2008, the SEC issued an Interim Final Temporary Rule, Exchange Act Release No. 34-58785 extending the reporting requirements for institutional investment managers concerning information on daily short sales and short positions of certain publicly traded securities.

Specifically, an institutional investment manager who has filed or was required to file a Form 13F under section 13(f) of the Exchange Act and Rule 13f-1(a) thereunder is required to file a report on a new Form SH with the Commission stating their short sales on a weekly basis. (Form SH Instructions)

ACN offers an EDGAR Filing Agent Service to those managers, as well as law firms and compliance firms representing institutional managers who are required to file the Form SH. The cost of the service to submit the report to EDGAR is $150, $50 for a Notice Report and $75 for an Amendment. There are two reports that must be submitted - the Cover Page / Summary Page formatted as either text or HTML and the Information Table formatted as an XML file.

Send us your Entries Table / spreadsheet and we will do the rest. ACN will compile the report and create an XML file both of which adher to the EDGAR specifications. We will send you a text file / Proof for your review and approval and, upon your acceptance, submit both the Cover Page / Summary Page and the XML file / Information Table to EDGAR. You will receive an emal notification from the SEC/EDGAR that the report was Accepted. We do not require a contact. Upon the email Acceptance Notice from EDGAR we will send you an invoice.

It is important that you notify ACN by email (info@netacn.net) of your intent for ACN to act as your EDGAR Filing Agent and submit your Form SH so that we are prepared to handle it in a timely manner. We will provide you with a spreadsheet template for compiling your short sale entries.

ACN Form SH v 1.0

We offer a software program which will assist the investment manager in compiling the Form SH Report - Cover Page and Summary Page formatted as a text file and the Entries Report formatted as an XML file which is in accordance with EDGAR specifications. The software includes a template and an Access Runtime Database Engine behind it for saving, importing and exporting your data. The software also offers you the ability to compare the entries against the Official List of 13F Securities and remove all non-13f securities from the report.

The software is availabe in anindividual manager license as well as multiple/institutional licenses for compliance firms and law firms.

Please contact if you need further information or visit the ACN Order Page to order and download the software.

Reference the SEC links below for the complete rules and related instructions:

New Emergency Short Sale Order -
http://www.sec.gov/rules/final/2008/34-58785.pdf

Guidance Regarding Disclosure of Short Selling - Frequently Asked Questions http://www.sec.gov/divisions/marketreg/shortsaledisclosurefaq.htm

Technical Guidance Regading the EDGAR Submission of Form SH - http://www.sec.gov/info/edgar/ednews/formshsubmission.htm

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