Rule 13h-1 under the Exchange Act, which became effective October 3, 2011, requires all “large traders”20 to file a Form 13H with the SEC promptly after effecting transactions that reach the prescribed trading activity level. Large traders are required to update their Form 13H on an annual basis within 45 days after the end of each full calendar year. The annual fi ling must show any changes to the information contained in Form 13H that have occurred during the applicable calendar year. The SEC staff has confi rmed that large traders are not required to submit an annual fi ling for calendar year 2011. Therefore, large traders will need to submit their fi rst annual filings for calendar year 2012 on or before February 14, 2013.