ESMA_QA_1924

Status: ✅ Answer Published

Link to ESMA Q&A tool: https://www.esma.europa.eu/publications-data/questions-answers/1924

---

Regulatory Context

Regulation : SSR

Level 1 Regulation: Short Selling Regulation (SSR) Regulation (EU) No 236/2012

Level 2 Regulation: No information available

Level 3 Regulation: No information available

Topic: Other SSR-related topics

Subject Matter: Net short positions - Reporting by funds managed by the same management entity

---

Question

Submission Date: 10 October 2012

Are funds (or portfolios under management) managed by the same management entity expected to report net short positions?

---

ESMA Answer

Answer Date: 10-10-2012

[ESMA70-145-408 SSR Q&A, Q&A 8.1] No. At individual fund (portfolio) level, only the calculation of the net short position for each particular issuer takes place. Only the positions of the funds that are net short in the particular issuer i.e. pursuing the same investment strategy (i.e. being short), should be aggregated to determine the net short position at the management entity level and whether a threshold is reached warranting thus reporting and, where relevant, disclosure of the aggregated net short position in that particular issuer (see below).

For the purposes of the Regulation, an investment strategy is whether the fund (portfolio) is long or short in a particular issuer.

---

This document was automatically extracted from the ESMA EMIR Q&A database.