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More Commentary on the SEC letter to the NV court clerk...

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Posted by:   bobo 5/24/2006 5:41 AM

This is the letter to which these comments refer - the "Bloom" letter to the Nevada court clerk, as a follow-up to the NCANS and NASAA amicus briefs.

First, we have, from the Motley Fool message board, a comment rebutting another poster's perspective (and the SEC's) that the states have no right to adjudicate matters involving the DTCC's operations in their states.

"In the spirit of the debate, let's take a look at UR's logic:

"...federal law governs the securities markets, that state laws and courts are pre-empted from evaluating claims, because federal law trumps state law, and federal law makes the SEC the arbiter of such claims. I'm sure an attorney could describe it better and more finely than that, but I think I have the general idea correct. "

False. The securities markets are governed by federal and state law. If you really believes the statement that, "federal law governs the securities markets, that state laws and courts are pre-empted from evaluating claims," then what do state departments of commerce do? By this logic, there is no reason to have state regulators or state law (or, by extension, states).

Do you believe a state has the right to regulate the quality and kind of air pollution cars can emit? If not, then tell California, which has more stringent standards than do the feds.

"Apparently "B'DB'O'B" doesn't think the SEC, the regulatory body for the financial markets, should be allowed to express its opinion to a court about a court case involving the financial markets, and the matter of that court's jurisdiction."

This is a straw man. Bob's point wasn't that "they should [not] be allowed to express" their opinion. It is that formal legal pleadings follow a certain form, and that form is not, "I'll send a private letter to the clerk of the court."

Lastly, by the SEC argument, no federal regulator can ever fail because whatever it does "becomes" what it is supposed to do by dint of the fact that that is what it did. So if the EPA ignores a person dumping millions of gallons of raw sewage into the Colorado River, no state law against pollution can be applied in state court, because the EPA has done nothing about it."

Pretty succinct, I think. The SEC is patently in the wrong here, and doesn't have a leg to stand on, IMO. Which is why the letter to the court clerk doesn't have any citations, or support, for its declarations. It simply makes pronouncements as to what it wants the court to believe, and then demands that the court heed those words, or risk unleashing the dogs of chaos - an unimaginable world where a privately owned corporation (the DTCC) would be answerable to fraud charges in the states it does business.

Can't have that.

A friend of mine, who is a former SEC guy, had this to say about the letter:

"I think the Motley Fool rejoinder is dead on. 

The only addition I'd offer would be to point out that in every, every, major scandal unearthed and dealt with since the mid-eighties, states initiated the action that brought down the house. And their primary tool was state anti-fraud securities laws. You name it: limited partnerships, in the 80's; market timing in mutual funds; "independent" analyst frauds--all of it, state initiated, home-grown, using the very fraud laws the SEC now says are preempted because someone in the bowels of the SEC endorsed the rules of a trade association licensed with the SEC--not even their own rules, but those of the DTCC--a mere licensee. 
 
State securities laws predate their federal counterparts by decades. God help us if some state or federal judge ever rules that state fraud laws are somehow preempted by something like the SEC's endorsement of a licensee' internal rules. Congress knows the value of those laws and even in preempting other regulatory aspects of state securities law, it has never touched the third rail of preempting state anti-fraud provisions. 
 
The second point, involving the lack of the SEC's adherence to court rules and  procedure, is really the more striking than the ranting arguments made in their letter. Having any legal experience at all, you are left speechless--blinking back the tears. Former SEC attorneys are blinking back the tears for a different reason.... You begin to think, "Hey, why did I spend all that time formatting, providing numbered lines to the text, getting the right colored paper, providing a table of contents, table of authorities, getting the margins right and meeting the deadlines (and on, and on, and on...) when only a two-pager to the court clerk would do?  Maybe I could just pick up the phone...."  etc.
 
It is fascinating to me that an agency that requires strict adherence to its own rules, regulations and procedures would think  it appropriate to ignore those of another branch of government."
 
That is one of those classic commentaries where you are left thinking, "I wish I had said that."
 
These are not the only erudite comments I have received privately. But they do have a certain resonance, and I wanted to share them with you, as it is easy to believe that we are living in a vacuum - a dictatorship where whatever the central government mandates becomes the order of the day, and no divergent view is tolerated.
 
Again, I find this whole thing remarkable, in the sense that we now have a very real civil war within the regulatory framework, with the state regulators coming down on the side of due process and investor rights (and against protectionist Imperialism), and the SEC coming down on the side of secrecy, protectionism, and curtailing of state and investor rights and redress.
 
This really is wild, if you think about it. How out of whack does the system have to be when the 50 states are basically saying, "Enough"?
 
 
Copyright ©2006 Bob O'Brien
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Comments (19)
Re: More Commentary on the SEC letter to the NV court clerk... By CMKXBULL on 5/24/2006 9:42 AM
This post has been relocated to the CMKX forum, as it is off-topic to this blog's subject matter. Please post any copies of attorney communications to CMKX shareholders in that forum, not in the general blog, as difficulty obtaining certs is not the topic of a blog disussing a letter from the SEC. Thanks for your consideration of the blog's etiquette.
Re: More Commentary on the SEC letter to the NV court clerk... By Mr. Wiggle on 5/24/2006 9:13 AM
Protectionism by the Federal govenmen? Look at that other licensee Fannie Mae and how little has been said about that scandal that eclipses Enron. Why aren't the board of directors caught up in that scandal out of the public eye?
Re: More Commentary on the SEC letter to the NV court clerk... By tommytoyz on 5/24/2006 9:45 AM
The SEC will be sued directly, just like the EPA and other federal agencies and rule making regimes have been successfully sued in the past.

1. There are federal laws written by congress that the SEC is not enforcing
2. Certain SEC rules are in direct conflict with laws written by congress
3. States can step in when the SEC won't, so long as the state laws being applied are not in conflict with federal laws

This really is akin to some entities dumping toxic trading, data and manipulation onto the investing public located in all 50 states and the SEC is actually defending the practice.

So the states have to step in and the SEC needs to be sued directly for the rules and practices it formulates that directly conflict with the law written by congress a long time ago.

This is a long time coming to the arrogant Wall Streeters.
Re: More Commentary on the SEC letter to the NV court clerk... By Patchie on 5/24/2006 9:48 AM
Bob,

The most appalling issue pertaining to this memo is that it is nothing short of factual inaccuracies and misrepresentations.

First. The SEC claims SHO is working when the data does not support such accusations. The number of companies listed today is less than what was listed on January 7, 2005 but is more than what was on the list in April 2005. The goal was eventually reducing to zero which is not the direction the law is moving to. The memo claims that the SEC will persue changes if changes are necessary but if they put their blinders on and deny the results there is no intent to change.

Second. The memo claims that the SEC is following the direction of Congress when in fact SHO was not what Congress suggested. Lawranne Stewart (aide to Barney Frank of House Financial Services) has repeatedly informed the SEC that the grandfather clause makes no sense. The clause also violates the "prompt" in prompt and accurate settlement as defined in 17A, 15c3-3, 15c6-1.

Third. The memo fails to identify how long the SEC has overlooked this issue and how long the SEC has worked to protect the institutions from violations of the laws. There is a defect and that defect has been recognized by the SEC while this memo denies a defect exists. Reference the opening comments of the General Counsel of Bear Stearns.

"To give you that brief introduction in Reg SHO, the history (of) how we got to where we are today. For the past few years we have been hearing from many different regulators regarding their concerns about the increase in the level of fails that they are seeing. They believe, and they have stated on numerous occasions, that one of the primary causes of the high level of fails was that various participants in the short sale process, prime brokers, executing brokers, clients, were not following already established rules."
Re: More Commentary on the SEC letter to the NV court clerk... By Patchie on 5/24/2006 9:55 AM
tommy,

I do not disagree that the SEC should be sued. It is a difficult venue but...the suit would be aiding and abetting as they have created law that hurts the investor for the financial benefit of the criminals. Those listed in the lawsuit would be the Chairman, Commissioners, and the Directors of Enforcement and Market Reg.

I believe the comments made by Bear Stearns and what could be accessed through certain Congressional Member meetings, we could accumulate evidence that the SEC created an illegal federal bail out program.
Re: More Commentary on the SEC letter to the NV court clerk... By rtway1 on 5/24/2006 11:06 AM
I,ve made this comment before and I think it makes more sense now after reading Patchies post. Nobody wants to pony up the money for the lawsuit and if all we ever do is talk about it nothing is going to happen. What about calling or presenting the facts to the ACLU to sue the SEC on the behalf of the public. Obviously I am not a lawyer, but I would think the SEC would not want the press that would come with this move, especially in an election year.
Re: More Commentary on the SEC letter to the NV court clerk... By tommytoyz on 5/24/2006 11:24 AM
The lawsuit should be made by NCANS and a call for donations would yield plenty of money, I'm sure of it. WHen NCANS was just founded there was enough money raised in a week or so two pay for two half page Washington Post ads and also the Amicus to the Nanopierce lawsuit.

NCANS is a powerful vehicle, like the Sierra Club is to the environmentalists. If other entitles later want to join us in the lawsuit, I'd say they're welcome. Like the NASAA and others that share the vision of cleaning up Wall Street, getting rid of the ridiculous SEC rules that aid only the big boy Wall Streeters and imposing the same laws and rules on everyone, without exception.
Re: More Commentary on the SEC letter to the NV court clerk... By teacheric on 5/24/2006 11:29 AM
i think this law suit may cost just a bit more than 2 pages in the newspaper. We need deep pockets.
Re: More Commentary on the SEC letter to the NV court clerk... By ginger on 5/24/2006 11:40 AM
Intelligence Czar Can Waive SEC Rules
Now, the White House's top spymaster can cite national security to exempt businesses from reporting requirements

http://www.businessweek.com/bwdaily/dnflash/may2006/nf20060523_2210.htm?campaign_id=rss_daily
Re: More Commentary on the SEC letter to the NV court clerk... By Patchie on 5/24/2006 12:24 PM
Tommy,

It's not even about just money. I have tried to get certain lawyers involved in this to sue the SEC for 2 years now and they do not want to touch it.

It is my opinion that all defendants should be put at the same table (DTCC, SEC, Institutions) and let the judge sort out blame and punishment. The SEC memo simply states what the DTCC would use in a lawsuit - "We are dioing what the Federal Govt said we could do". Let that comment result in a finger point to the defendant standing next to them instead of to an unnamed defendant.

BTW...I found this in the Sanity Forum section earlier today. It certainly challenges the memo drafted by the SEC general Counsel.

SHORT SELLERS/MARKET NEUTRAL INVESTORS - SEC RE-EXAMINING RULES ON NAKED SHORT SELLING: An SEC official last week indicated that the SEC is actively examining the issue of naked short selling by investors (selling short without having the securities in portfolio or a borrow arrangement in place). James Brigagliano, assistant director in the SEC's Division of Market Regulation, indicated that further rules changes may be undertaken by the SEC to thwart illegal naked short selling . While this issue was suppose to be resolved last year with the implementation of Regulation SHO, market data indicates that this regulation only moved illegal naked short selling to other venues. Regulation SHO does not prohibit naked short selling but has a variety of provisions designed to thwart a failure to deliver on a naked short sale. Possible amendments to this rule could include a requirement that all short sales be covered by a borrow of the shares prior to the short sale, as well as more transparency regarding failures to deliver on naked short sales.

http://www.gtlaw.com/practices/corporate/roundup/PrivateFundsWeekly_v1No14.pdf
Re: More Commentary on the SEC letter to the NV court clerk... By Allan M on 5/24/2006 12:32 PM
The letter screams GUILTY. It screams there's big problems and the public can't see what's under the bed.

Slightly OT but... Anyone read in the WSJ where sen. Shelby was quoted, talking about the fannie mae scandal. Here's a nugget, Shelby says; "Clearly, the report shows that left to their own devices, the [two companies], at best, are willing to neglect this mission and at worst, abuse their unique status to line their pockets".

So I guess sen Shelby does understand a little about human nature. The DTCC kind of has a unique status as well. I wonder if they're left to their own devices if they might be tempted to abuse their power and line their pockets as well? Hmm.
Re: More Commentary on the SEC letter to the NV court clerk... By harryofanguslane on 5/24/2006 12:33 PM
We have every reason to believe that there are good and decent people at the SEC that joined it because they believed in fair securities markets. No doubt, they are as disgusted as we are.

And here's an idea from way out in left field. The SEC letter to the Nevada Court was so egregious that it almost seemed designed to thoroughly piss off the trial judge. Could someone in the bowels of the SEC, knowing that his/her masters were doing squat, want that very pissed off feeling to occur?
Re: More Commentary on the SEC letter to the NV court clerk... By Wonder Boy on 5/24/2006 12:38 PM
With due respect to all concerned, I really do not think we need more 'thwarting' from Mr. Brigagliano. What we need is SETTLEMENT. It is actually a very straightforward concept and should not be too difficult for the SEC to follow----give me what I PAID for! If you can't manage to do that, then pay me $100/day/share that you have artificially created, or do not take my money until you can deliver and give me the option to cancel until delivery.
Re: More Commentary on the SEC letter to the NV court clerk... By mhelburn on 5/24/2006 1:42 PM
"The Commission has adopted Regulation SHO for the purpose of preventing abusive naked short-selling and it has stated tht if it concludes that further steps are required, it will take them."

Prevention, by definition of the way the SEC is working, is grandfathering all the previous fails. Nobody in his right mind grandfathers illegal activity as a means of prevention. When Reg SHO was implemented, they already had a serious problem and instead of setting deadlines for these fails to be corrected, we have watched for 17 months the continuous abuses to which they refer.

The NYSE has fined one participant for misinformation about their failures and the false information that has been presented. If one participant can be sooo wrong for so long, how can the NYSE, the SEC or anyone trust any of the reporting?

GIGO and the joke continues. It is obvious that the SEC has no intention of doing anything about the abuses.. or rather they have concluded that this larceny is acceptable. If the States don't get involved, the SEC will continue to conclude that Reg SHO is working. It is working only if it was done to prevent any improvement in the clearing and settling of trades. Reg SHO is a fraud and a pretense. Eliminate the stock borrowing program at the DTCC and there would be no way for the fails to continue to plague the system. Borrow the shares from owners.. not from the DTCC. No borrow, no short-sale. If owners don't want to lend shares, the DTCC has no business creating shares for market manipulation.
Re: More Commentary on the SEC letter to the NV court clerk... By tommytoyz on 5/24/2006 1:49 PM
I don't think a lawsuit against the SEC would be very expensive, as no discovery, etc, is required. It's a matter of simple law.

The laws of the 1934 Securities Exchange Act say one thing and the SEC and SRO rules say another. Simple. So who preempts?

It's a matter of the 1934 Securities Exchange Act preemting any conflicting SEC rules or SRO rules. Period. The law is already there and very well and clearly written.

It's not a terribly complicated matter or case to argue in my mind. The SEC and SROs will certainly create a mind splitting complex defense. But the simple truth is on our side. The 1934 Securities Exchange Act rules over the industry and no SEC rule can be enforced if it conflicts with any provision of the Act. Period.

The SEC does not have law making ability, only Congress does. Federal laws will always preempt federal rules, if they are not consistent with each other.

A law student could argue this case, IMHO
Ralph Nader's organization might take the case By FYI on 5/24/2006 4:48 PM
http://www.citizen.org/litigation/
Re: More Commentary on the SEC letter to the NV court clerk... By hhawes on 5/25/2006 4:23 AM
I see where Utah legislators passed an anti NSS bill and sent it to the Governor to sign. Do you think Cartwright will be sending the Governor a similar letter?
Re: More Commentary on the SEC letter to the NV court clerk... By ginger on 5/25/2006 4:58 AM
Bill would crack down on illegal 'naked short selling'
Overstock.com would benefit: Transactions meant to affect stock prices are targeted in a measure now before Huntsman

By Bob Mims
The Salt Lake Tribune

Article Last Updated: 05/24/2006 11:23:50 PM MDT

Overstock.com and other small, publicly traded Utah companies concerned about so-called "naked short selling" got a boost when state legislators voted Wednesday to crack down on the illegal practice.

With little debate, SB3004 quickly wound its way to overwhelming approval in both the Senate and House during Wednesday's special session.

"I'm glad to see Utah is taking this vanguard role," Overstock Chairman and CEO Patrick Byrne said. "And I predict this will make Utah the most attractive state for entrepreneurs and small companies in America."

Now awaiting Gov. Jon Huntsman Jr.'s signature, the law would get tough on stock brokers, dealers and investment advisers who engage in naked shorting of stocks - an illegal practice in which shares supposedly on loan are sold but not delivered.

Such "failure to deliver" transactions can result in counterfeit volume that can push down prices for a company's real shares. SB3004 would require sellers caught in such unredeemed short sales to report the incidents to the Utah Division of Securities - and reveal the identities of sellers and buyers, along with dates, locations and prices involved in the bogus transactions.

The bill calls for daily fines ranging from $10,000 to the sum of the sales prices for every bogus share sold. The bill also allows for victimized companies to sue perpetrators of the sales - but only as long as the alleged offending stock firm is registered in Utah.

Sponsoring Sen. Curtis Bramble, R-Provo, is uncertain how effective the law will be outside of Utah. But he hopes other states - and the federal government - will follow suit.

Overstock currently is embroiled in a California state lawsuit against market researcher Gradient Analytics and hedge fund Rocker Partners. The Utah company claims Gradient wrote false reports about Overstock in collusion with Rocker, which then profited by short-selling the company's stock.

Bramble insisted his bill was not just to appease Overstock, a $1 billion company employing thousands of Utahns.

"It's not only [Overstock Chairman and CEO] Patrick Byrne," he said. "This is a problem that exists for all of Utah's publicly held companies when these 'bad actors' engage in illegal naked short selling."

Still, lawmakers clearly knew Wednesday that Byrne badly wanted the legislation: He said so in a letter sent to lawmakers.

"For the past 17 months, Overstock has shown up almost daily on a list published by [the Nasdaq exchange] that shows that Wall Street sharks are selling our stock to unwitting investors, taking their money, but then not delivering the promised stock," Byrne wrote in a letter dated Tuesday.

"I have been unable to stop this illegal activity," added Byrne. "I cannot even determine the identity of these miscreants or the actual volume of 'fake' shares sold each day. I believe transparency is crucial."

Utah Securities Director Wayne Klein agrees.

He said his division is engaged in "gathering information from the industry about short selling practices to determine whether violations are occurring now and, if so, what enforcement actions should be taken."

A nearly identical bill (SB269) fell short of a final vote in the House as the general session expired last March.

bmims@sltrib.com
Re: More Commentary on the SEC letter to the NV court clerk... By mhatmccane on 6/2/2006 12:02 PM
So, the next question is how much impact will the Whistler case decision in Federal court have? I'm still looking at the SCOTUS decision regarding "enabling" legislation for SEC rules (such as SHO and "grandfathering" ).

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