Regulation SHO

You must inform GTN prior to effecting any short sale. GTN will inform you whether it is able to locate or pre-borrow the shares that are to be sold short. You may rely on any lists that are provided by GTN, 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 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.


Pursuant to Regulation SHO, you are also required to properly mark your sale orders, whether Long or Short. 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.


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