"Don’t Get Caught Short by Rule 105: A Refresher for Hedge Fund Managers" by Scott Budlong and Michael Mann

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August 27, 2013

Rule 105, the SEC’s tool to deter manipulative short selling in connection with public equity offerings, continues to be a source of concern for hedge fund managers. In this memorandum, Richards Kibbe & Orbe LLP partners Scott C. Budlong and Michael D. Mann explore the contours of Rule 105 and offer compliance guidance for managers who sell short as part of their investment strategies.

Download memorandum.