Commission Guidance on Rule 3b-3 and Married Put Transactions

The Securities and Exchange Commission is publishing interpretive guidance on calculating a "net long" position under the Securities Exchange Act of 1934 when using married put transactions as a part of certain trading strategies. A seller of securities is required to aggregate all of its positions in that security to determine the seller's "net long" position. Determining security ownership is an essential component to aggregating security positions under the Securities Exchange Act of 1934. The guidance we are publishing today clarifies the determination of security ownership when married puts transactions are used.