Regulation SHO

When you effect any sales of securities, you are responsible for ensuring that the sale is properly marked as Long (if you own the securities) or Short (if you don’t own the securities). If you may have a potential issue in marking your sales orders properly (e.g. due to latency or other operational or strategic issues), you are required to consult GTN’s Compliance department prior to effecting such orders.

Any Short sales require that the security has a Locate to commensurate with the amount of shares that you are selling short.. You may rely on any lists that are provided by GTN (or its clearing firm), i.e. easy-to-borrow and/or hard-to-borrow; provided, however, that the list are in effect only for the day, i.e. you may not rely on a list obtained from GTN (or its clearing firm) from previous days of the contemplated short sale. If you represent to GTN that you have located the security within the meaning of Rule 203 of Regulation SHO, GTN may rely on your locate. In those instances, you must provide copies of the third-party locates to us.

If you have any questions about this policy, please write, call, or email us.

32 Old Slip, Suite 3200C

New York, NY  10005

Call us: +1 332 230 1184

Email: compliance@gtnamericas.com