Large Trader Reporting Law
(Large Trader Status)

Large Trader Status, Form 13H, and LTIDs. Rule 13h-1(a)(1)(i) defines a “large trader” generally as any person who directly or indirectly (including through other controlled persons) exercises investment discretion over one or more accounts and effects transactions in NMS securities for such accounts, through one or more registered broker-dealers, in an aggregate amount equal to or greater than the “identifying activity level,” defined as aggregate transactions in NMS securities* that are equal to or greater than:

  • 2 million shares or $20 million in a calendar day; or
  • 20 million shares or $200 million in a calendar month (Rule 13h-1(a)(7))

A large trader must self-identify by filing Form 13H with the Commission through EDGAR, providing certain information about its operations (including a general description of trading strategies), whereupon the Commission will issue a large trader ID number (“LTID”). A person or entity also may become a large trader by voluntarily registering as such, without regard to the trading thresholds above – for example, to obviate the need to monitor its trading activity on an ongoing basis. (Rule 13h-1(a)(1)(ii)) A large trader must disclose its LTID to each broker-dealer that effects transactions on its behalf.

* NMS security is defined in Regulation NMS, Rule 600(b)(46) as “any security or class of securities for which transaction reports are collected, processed, and made available pursuant to an effective transaction reporting plan, or an effective national market system plan for reporting transactions in listed options.” See Rule 13h-1(a)(5).