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NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem

Location: Blogs Bob O'Brien's Sanity Check Blog    
Posted by:   bobo 10/12/2006 9:37 AM

Sign the Market Reform Petition Now!: View it here.

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Without too much preamble, I would strongly advise everyone to read this comment letter from NASAA to the SEC.

Contrast it to the self-serving demands for special consideration coming from the industry.

Contrast it to the idiotic, one-sided spin from "trusted sources" like Wikipedia, or Herb's buddy Dick Sauer at Rocker Partners, who recently wrote his short seller apologist piece for the NY Times (covered a few blogs ago).

This is the product of the entity that represents the state securities regulators - NASAA. It is an organization of specialists in securities regulation, who are more than able to differentiate between imaginary, trivial voodoo, and legitimate and very real threats to the market.

What to make of the letter's blunt statement that the DTCC is obstructing justice and the investigation into NSS? How to reconcile the DTCC and SEC's statements that Reg SHO is "working" with NASAA's point blank admission that FTDs are now on the increase - something we've been aware of since Dave Patch got the FOIA data in? Where do the liars and industry scammers hide, now that NASAA highlights, in black and white, that this is a very real, very serious threat to any faith in the integrity of the markets? How do we reconcile the market reform movement's having been called a "cult" of "conspiracy theorists" by the industry's lapdogs, when the organization of securities regulators is saying that we have been 100% accurate in our assessment? Do you think we will be reading any articles in the WSJ or NY Times or Barron's on that...?

How many articles do you think we will see that highlight this letter's concerns and recommendations? Do you think it will be allowed to be linked at Wiki? Will the NY Times run an op ed column saying enough is enough, citing this remarkable document?

Folks, send this link to every reporter and elected official out there, and demand coverage and action. The states spell it out in no uncertain terms. This isn't the Easter Bunny's comment letter. There really is no more qualified group out there, and the letter is unambiguous in its conclusions - the problem is getting worse, not better, under Reg SHO, it significantly damages the integrity of our market system, it is a real problem, and it must be addressed or the whole house of cards can come tumbling down.

That should sober even the most glib apologist. But it is up to us to get it out there to journalists, and elected officials. So do your part.

And sign the damned petition, already...

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A poster on InvestorVillage highlighted the following passage from the letter, that says what should be obvious to even the dimmest bulb at the SEC, and yet which is so studiously avoided by those "experts":

"If we were to choose between the risk of customers not receiving shares they have purchased (along with the related consequences of deliver failures) and the risk that traders might be the subject of a short squeeze, we will choose the latter. Traders are in a much better position to protect themselves than the investors who have relied on market participants to execute their orders. The fear of being a victim of a short squeeze or the possibility that volatility will make it more expensive to cover a short position are the "natural consequences" of the conduct of these traders. To the extent that the current regulations protect traders from the risks and attendant consequences of short selling conduct, the regulations encourage abusive conduct. Short squeezes would be an effective palliative for sellers who have failed to deliver on contracts they have made. Volatility is the market’s natural and proper response to uncertainty regarding secret conduct of short sellers."

Well, hallelujah, and no sh$t. Being a fraudster can be corrected by the market, which will punish it, if allowed. What a novel idea.

Of course, Wall Street's fraudsters are dead set against that idea, as is the SEC. What does that tell you?

Copyright ©2006 Bob O'Brien
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Comments (68)
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By tommytoyz on 10/12/2006 11:25 AM
I like the NASAA a lot. It is a great and very detailed letter no doubt about it.

But unfortunately, the NASAA proposals still allows options market makers to hedge their option positions at the expense of equity holders. I'm surprised at this. In their letter there is also no mention of the 1933 and 1934 Securities Acts. All FTDs are illegal according to those Acts.

I like the proposals by the NASAA, but they don't go far enough, as they propose to keep the market maker exemption open. I guess old habits die hard. But to be perfectly fair and to avoid all the FTDs they talk about, the market maker exemptions also must be closed.

There is just no way to justify it in my mind as it not only gives certain parties trading advantages over others, but these advantages come at the expense of already existing equity owners (not traders).

I also saw only a passing reference to the ex-clearing/security entitlement issue as brokers increase the securities available for sale in larger numbers than actually exist. In reality it's much worse. Brokers don't merely offer for sale what does not exist, the actually credit what does not exist in customer accounts via Security Entitlements or electronic float - which represent no real securities. The NASAA is a little behind the curve on that problem, IMHO.

So a thumbs up for the NASAA letter, but they should have gone a little further and stopped ALL FTDS period - with no exemptions to the 1933 and 1934 Acts. Period.

But a great letter explaining the problems in detail...........
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By tommytoyz on 10/12/2006 11:30 AM
What I really like, besides their very detailed analysis of the problems and their effects, is the issue about over voting. How can companies govern their affairs if share holder votes are never accurate? The most fundamental issue regarding corporate governance?

Besides the few loopholes they leave open, it's a stunning letter.........
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By InTheKnow on 10/13/2006 5:13 AM
The letter in a nutshell:

SETTLE THE TRADES and SETTLE THEM NOW!
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By discreet stinky shit on 10/13/2006 6:09 AM
Five conservative nonprofit organizations, including one run by prominent Republican Grover Norquist, "appear to have perpetrated a fraud" on taxpayers by selling their clout to lobbyist Jack Abramoff, Senate investigators said in a report issued yesterday.
The report includes previously unreleased e-mails between the now-disgraced lobbyist and officers of the nonprofit groups, showing that Abramoff funneled money from his clients to the groups. In exchange, the groups, among other things, produced ostensibly independent newspaper op-ed columns or news releases that favored the clients' positions.

http://www.washingtonpost.com/wp-dyn/content/article/2006/10/12/AR2006101200889.html?nav=rss_print/asection
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By infinitesupply on 10/13/2006 6:12 AM
They want investor's money.

When a stock is fairly valued, there aren't as many buyers as when it is trading at 90% below book value. By pushing the price down, they encourage investors to give them their money.

By pushing the price down, they create way more demand and that money is transferred to the counterfeiters. Since they can create infinite supply, they can hold the price there forever and keep your money.

Sure, they have to put collateral up, but it cancels.

House A owes $10 million to house C
House B owes $10 million to house A
House C owes $10 million to house B

cancels to no one owes anyone anything, but they all have the proceeds of the $30 million in counterfeit sales they can pocket.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By infinitesupply on 10/13/2006 6:17 AM
The cause of many of the problems is "netting" which reduces transaction volume by 96%. As a side effect, it takes away the ability to audit / regulate the process and allows any participant to print money / shares out of thin air.

Netting made sense when there were no computers, but even quadrillions of transactions are no problem for a good server farm. Why do we need to net?

If it is such a good idea, why doesn't google do that? They could net all the searches through the day, providing the results once in an omnibus search result?

If google can do trillions of searches, then the new system that replaces the DTCC should be able to do trillions of trade matches, each with an auditable trail.

Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By infinitesupply on 10/13/2006 6:46 AM
It's like the FEMA beuracrats in New Orleans. You shouldn't have unqualified political appointees structuring something as complicated and important as a clearance system.

None of the commisioners are qualified (or motivated) to set up a system to protect investors.

You need mathematicians and scientists to model the system rather than the Nazareths of the world trying random rules based on comments from the peanut gallery.

With modern computers, it is possible to process every transaction without netting, keeping an auditable obligation for both sides of the transaction.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By bobo on 10/13/2006 6:47 AM
Infinite: Great point. The netting impact is one of the largest problems in terms of accountability. And whether by design or circumstance, it now enables an entire generation of thieves to steal our retirements, without any audit trail. The DTCC knows and understands this, and seems as though it wouldn't have it any other way. WTF. WTFF.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By mhelburn on 10/13/2006 7:13 AM
Disreputable client shorts or sells long shares that the dog is chewing on. Someone in margin at the same firm buys.... no problem.. take the share entitlements just purchased by number 2 and lend them to client number one....No need for outsiders to know that it is all airshares.. thank-you CNS. CNS, Stock Borrow Program, desking trades, ex-clearing.....
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By bobo on 10/13/2006 7:22 AM
Actually, mary, that is pre-netting you just described. CNS netting would be after that farce took place, if the broker didn't have enough air shares to net within his little group, and say 1000 fails went into the CNS system. There, those 1000 would be netted against his total shares held long, resulting in an adjustment down in that number, but still no fail hitting SHO. It is only after CNS has used up all the shares held long, and offset them with fails, that the first FTD would hit.

Anyone that understands all the netting, desking, SBP, ex-clearing, open positions, etc. reels with the level of possible fraud...
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By golfwalt on 10/13/2006 7:40 AM
broke flat:

Maybe, but I still don't think the exceptions are reasonable. What about those situations that the MM wants to extend the failed sells indefinitely? What if he wants to hedge his position for LEAPS? What about when he wants to roll his FTDs over indefinitely to cover a new round of options? This simply leaves the door open and puts us right back where we are now.

No, I still say, 'No exceptions'.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By clearthinker on 10/13/2006 8:02 AM
and how to prove it? Stop the game of musical chairs. Halt trading in some of the companies that allege counterfeiting, and have the Justice department subpeona the shareholder lists of EVERY single brokerage firm in the world and find out how much stock is owned vs. the authorized...

Now you understand why this is such a hard crime to prove....
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 8:03 AM
Another repost, but important for everyone reading this to understand how this happens OVER and OVER at various levels...

A) Buyers and sellers at an introducing brokerage are netted and applied to the existing long position.

Example 1:

Sally wants to buy 1,000 shares, but no one wants to sell and the house has 10,000 shares in inventory all belonging to real customers. They "desk" the trade to Sally. One of their own customers now has 1,000 phantom shares in their account. Customers think they own 11,000 shares, but the house only owns 10,000 shares.

Example 2:

Someone at the counterfeit sells 10,000 shares, but other buyers at the house buy an aggregate of 10,000 shares. The counterfeit sale is masked by the real long buys.

10,000 in inventory + 10,000 real purchases - 10,000 counterfeit sales = 10,000 in inventory.

No change is required to the house's inventory position (the house doesn't owe anyone anything) and the 10,000 sales are completely masked. Their own clients own 10,000 real shares and 10,000 phantom ones.

B) Introducing brokerages clear through clearing brokerages. The clearing houses treat the brokerages like customers and the exact same scam can happen at this level.

The bad brokerage effectively borrow long positions from the good brokerages that all hold their assets at the clearing brokerage. All the long and short positions at the various brokerages are netted at the level of the clearing house. Counterfeit trades can be masked at this level and the clearing house may have no outside obligation.

C) The Clearing Brokerage may net at a foreign depository. They can borrow from any other member in the depository. Note how the system is starting to get clogged up with phantom shares and we aren't even at the DTCC yet.

D) The foreign depository is a participant at the DTC and they net their trades with the CNS system. Because of the hassle of cross border transfers, they will avoid actually transfering any shares into or out of America, in most cases handling short falls from the stock borrow program. That means that huge trading in Canada or Germany could have a minimal short term impact on share prices as everything is dampened by stock loans and phantom shares.

E) If the stock borrow program can't cover up trading short falls, then they show up as "fails to deliver". SHO doesn't disclose these unless they exceed a threshold at one clearing accounts. Many Clearing Brokerages have multiple clearing accounts and can spread the fail over various accounts to stay below the threshold.

The threshold also doesn't apply to OTC and Pinks with less than $10 million in assets as they are not considered public companies under the rules.

Finally, even past all this obfuscation, 1% of $1 quadrillion fail to deliver. Most transactions are debt. The DTCC doesn't give us the exact numbers, but they disclose that equities are less than $130.7 trillion. I have a hard time not taking that to mean $10 trillion (1% of debt and equities) fail to deliver each year. I can't imagine equities being much higher than that, which makes me believe that possibly more than half the trades that occur each day are not real.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By hoagx on 10/13/2006 8:57 AM

AWYB NEWS!!! Approx. 21 Million Short!!!

"In my view, looking at everything I see, I think the shorts are in the neighborhood of 21 million shares." --Dandy Don Platten

American Way Business Development Corp. Updates Shareholders on NOBO List Market Wire - October 13, 2006 12:38 PM (EDT)

BOCA RATON, FL, Oct 13, 2006 (MARKET WIRE via COMTEX) -- American Way Business Development Corporation (PINKSHEETS: AWYB) ("AWYB" or the "Company") on Monday, October 11, 2006, announced that there appeared to be major differences in the numbers reflected on the NOBO list versus the actual numbers from the transfer agent. As we noted in our press release of yesterday, October 12, 2006, given the discrepancies, we felt we had no choice but to do a mandatory cert recall.

Mr. Platten, President, also noted that a lot of shareholders were asking for a specific number of shorts. We have been very reluctant to provide a number since we cannot be absolutely certain. There have been a lot of rumors in the past few days and the Company feels compelled to quell the rumors by providing its best estimate to date. In the words of Mr. Platten, "In my view, looking at everything I see, I think the shorts are in the neighborhood of 21 million shares. However," Mr. Platten adds, "whether my estimate is correct or not, the rubber will soon meet the road. We are hopeful that everything will be in place for the mandatory cert exchange by the end of the business day on Tuesday, October 17, 2006."

The Company believes that once the mandatory cert exchange is finalized it will resolve the shorts problem once and for all. We encourage our shareholder base to watch for updates as they occur.

This contains forward-looking information within the meaning of The Private Securities Litigation Act of 1995. Forward-looking statements may be identified through the use of words such as "expects," "will," "estimates," "believes," or statements indicating certain acts (such as "may," "could," "should," or "might occur"). Such forward-looking statements involve certain risks and uncertainties. The actual results may differ materially from such forward-looking statements. The company does not undertake to publicly update or revise its forward-looking statements even if experience or future changes make it clear that any projected results (expressed or implied) will not be realized.

Contact:
American Way Business Development Corp.
Don Platten
561-962-4124
donplatten17@aol.com
http://www.americanwaybd.com


SOURCE: American-Way Business Development Corp.

mailto:donplatten17@aol.com
http://www.americanwaybd.com

Copyright 2006 Market Wire, All rights reserved

Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By z3peru on 10/13/2006 9:05 AM
Idea. Hire Google and UPS to redesign the whole blame stock trading system. Then it will be fast, correct, and efficient.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Willie Loman on 10/13/2006 9:44 AM
Why is it that the public easily gets into a tizzy over electronic voting (and the attendant problems of voter fraud etc.), but when it comes to the vastly more complex area of electronic securities settlement (ahem, speaking of democratic voting principles), people are so willing to swallow the DTCC's and the SEC's soothing pablum to the effect that "it's a computerized system, and the computer is never wrong!"? Total apathy! Unbelievable...
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 10:04 AM
z3peru, I couldn't have said it better myself.

I think it is time to consider setting up a NON PROFIT organization to run every transaction through a central server farm on an audited, transaction based real time basis.

Rather than beg the DTCC to fix the problems, the politicians need to get rid of the beast altogether as an unnecessary relic of a time before computers. They've shown they can't be trusted and should have their cartel taken away from them.

All these layers of netting and long chains of beneficial ownership serve no one except crooks and money launderers.

Chains of beneficial owners should be no longer than central depository->brokerage->customer.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By cynabear on 10/13/2006 10:19 AM
Yes! z3 and Davidn! finally a solution I can get behind. Rather than more government let's get less! Can't we get Byrne and friends to start a competive market?
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 11:27 AM
Could Utah start it by requiring brokerages their to clear through a Utah based central depository that they can audit? The technology is not rocket science and the states need the authority to audit trades in their state...

1. Set up a Utah based depository. It would perform a similar role to Cede & Co., but would be government controlled / non profit. It would have certificated ownership at the company transfer agent that equalled the exact share position of all Utah brokerages.

2. All Utah brokerages are required to keep their ownership directly at that depository.

3. They could allow a bit of slop in the system so share certificates are only exchanged with Cede and Co. once per month, but once per month all Utah trades would be forced to reconcile.

Rinse and repeat until all states keep shares in state / non profit central certificates rather than letting Cede & Co. own them. We wrest control from the industry and return it to the public.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Willie Loman on 10/13/2006 11:51 AM
The DTCC would argue that the regulation of clearance has been federally pre-empted. But, I think states could make a STRONG case that the regulation of depository/custody has NOT been pre-empted. If states could just wrest those away from the DTCC, there would be no way for the naked shorts to continue their shenanigans
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By hole in my pocket on 10/13/2006 12:25 PM
A former floor trader at the New York Stock Exchange reaped $4.5 million in illegal profits by manipulating trades to cheat the Big Board's customers, a federal prosecutor told a jury on Friday.

http://biz.yahoo.com/rb/061013/crime_specialist_finnerty.html?.v=1
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Wicked World on 10/13/2006 12:57 PM

NOBO/OBO questions:

In reading the recent news items on awyb can someone help me understand who/what compiles the NOBO & OBO lists? I thought it was the Transfer Agent but now I'm not sure. And regardless of who has the list who else has access to it?

Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 1:12 PM
Wicked, it's hard not to be long winded in answering this, but I think it is important we all understand the process...

The company keeps a shareholder list at the company transfer agent. These are the real shareholders.

The list might look like:

Joe Smith 5,000 shares
Sally Jones 25,000 shares
'
'
'
Cede & Co. 50,000,000 shares

Cede & Co. is a privately owned partnership that acts as a nominee for the DTC.

The DTC keeps track of which DTC participants have a claim on these shares. Most participants are clearing houses. Those clearing houses keep track of which brokerages have claims on their shares. The brokerages keep track of which customers they owe shares to.

At the company's request to ADP, ADP sends a request out to the brokerages to tell them on the honor system how many shares their customers own. They only have to disclose the ones that don't object (NOBO = non objecting beneficial owners).

My observation is these lists tend to not be very accurate. A dirty brokerage will say all their clients are OBO's or they will scale positions to work out. It is not uncommon for brokerages to report a dozen shareholders totalling 100 shares, for example. That way they get 12 proxies as required, even though the brokerage only owns the 100 shares.

OBO is objecting beneficial owner.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 1:15 PM
To further clarify:

DTC sheet: a listing of the participants' claims on shares owned by Cede & Co. Most participants are clearing brokerages that act on behalf of other brokerages.

NOBO List: a voluntary list of actual customer positions gathered by ADP at the company's request. This list is provided by the brokers themselves on an unaudited honor system. This is only the customers that don't object to having their names known.

OBO List: generally not available.
broke flat - market maker exemption By tommytoyz on 10/13/2006 1:22 PM
No market maker should have exemptions to FTD. THis gives them an unfair trade advantage and doesn't solve the problem at all.

Look at foreign exchanges. There, options are hedged mostly via futures contracts. Why do we have to be different in the USA? Just because of habbit?

There are lesssons to be learned form other exhanges and evidence that they work just fine, better actaully. Remember that as a percentage of world invetor capital and IPOs - US markets are losing market share. That's not accident and shows that others foreign markets work very well indeed.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Wicked World on 10/13/2006 3:15 PM

davidn,

Thanks for the particulars.

To be clear, in your above example, ADP is the transfer agent, correct? One reason I ask is that in the case of ostk it appears ADP handled the sending out of the proxy votes yet "ComputerShare" (formerly Equiserve) is the transfer agent (according to PB's slides #17).

OBO. So how do I know if I'm OBO or NOBO? Your saying that the broker can lie (unaudited honor system) to the TA if need be. My question: Could that be audited if need be? Say some freak occurrence such as the SEC ordering it. Should/Would there be any paperwork to back any of that up as to who is OBO/NOBO? In the fine print of my cash account brokerage agreement might it say I forfeit my right to NOBO?

Transfer Agents. Being that no one is above suspicion, what is possible there?
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 3:21 PM
ADP is not the transfer agent. They just are the data processing company that gathers the information.

https://ics.adp.com/release11/public_site/products/invco/proxy.html

When you fill out your account form, they usually ask you if you want annual reports, etc. If you check "no", then they put you as OBO. Often, even if you check "yes", they will put you as OBO.

Your full name and number of shares shows up in the NOBO list. In my mind, they should list everyone (OBO and NOBO), but blank out the names for privacy.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 3:27 PM
Further to the proxy vote:

You don't get a vote at all. Only Cede & Co. gets a vote. Your brokerage solicits voting instructions from you, which are provided to the DTC who votes Cede & Co.'s votes.

As far as I know, there is no penalty for Cede & Co. not to follow your instructions and the process is anonymous and not audited. That makes Cede & Co. the controlling vote in most public companies.

They file an "ombibus proxy" on behalf of all the people they generously own shares for.

http://www.dtcc.com/ProductsAndServices/asset/proxy.htm

This is an important concept:

Cede & Co. is the actual registered owner. Only the actual registered owner has the right to vote the shares. They have a contract with you indirectly through a chain of contracts and if they don't vote according to instructions, they might ("oh no!") be in breach of contract.

People who have their certificates have the same voting rights as Cede & Co. People that don't will find they only get a fractional vote, scaled to reflect the phantom shares.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By hoagx on 10/13/2006 4:01 PM

Online brokerage account scams worry SEC

Fri Oct 13, 2:32 PM ET

WASHINGTON (Reuters) - High-tech crooks are hijacking online brokerage accounts using spyware and operating from remote locations, sometimes in Eastern Europe, U.S. market regulators said on Friday.
ADVERTISEMENT

The computer "incursions" are a growing problem, said Walter Ricciardi, deputy enforcement director at the U.S.
Securities and Exchange Commission.

"It's something we're very concerned about," he said in remarks at a legal conference in Washington.

About 25 percent of U.S. retail stock trades are made by online investors through roughly 10 million online accounts, according to brokerages regulator NASD.

Crooks will load a victim's computer or a public PC with a spy program to monitor a user's activities and capture vital information, such as account numbers and passwords.

The program then e-mails the stolen information back to the thief, who can use it to open victim accounts.

Once inside, the thief may sell off an account's portfolio and take the proceeds. Or electronically hijacked accounts may be used for "pump-and-dump" schemes to manipulate stock prices for profit, Ricciardi said.

Public computers in such places as Internet cafes and hotel rooms are especially vulnerable to incursions. But home computers may also be hit as spyware can be imported simply by opening an e-mail attachment, said John Stark, chief of the SEC's Office of Internet Enforcement.

Incursion scams under SEC investigation are far-flung. "We're seeing these frauds in offshore entities and persons, including those located in Eastern Europe," Stark said.

The SEC is working to track down the hackers and to educate online investors, he said.

Steps to fight incursions include securing an online account by changing passwords frequently and never using an unfamiliar computer to enter an account number or password.

To fight a similar problem, U.S. banks are exploring new online banking security technologies since a study showed identity theft via online banking is a fast-growing crime.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By InTheKnow on 10/13/2006 5:49 PM
When you want to rip everone off you make sure that you control the riparee!
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/13/2006 7:14 PM
The petition is just shy of a thousand names. Does that mean only a thousand people read this blog?

We need to find a way to share our understanding and knowledge about this crime with the masses.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By petition away on 10/13/2006 9:23 PM
We're only going to get any progress in courts. Keep up the lawsuit(s), it's the only way we are going to change things.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By unnamed others on 10/14/2006 6:18 AM
Nahmias's office said Shorbagi was a Georgia representative of the Holy Land Foundation and knew money provided to the foundation was actually funneled to Hamas.
According to prosecutors, between 1997 and 2001, Shorbagi provided financial support to Hamas, a group designated by the United States as a foreign terrorist organization. He also was accused of conspiring with unnamed others to provide material support to Hamas.
The donations were passed through the Holy Land Foundation for Relief and Development, prosecutors said.

http://www.washingtonpost.com/wp-dyn/content/article/2006/10/13/AR2006101300554.html?nav=rss_print/asection
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Justice Department working 24 hour shifts on 10/14/2006 6:37 AM
Statoil ASA, Norway's largest oil producer, agreed to a $21 million fine for paying bribes to try to win influence in Iran in violation of the U.S. Foreign Corrupt Practices Act.
Statoil's penalty is among the largest ever imposed by the U.S. for violations of the Foreign Corrupt Practices Act, a law aimed at preventing companies from paying bribes to win business overseas.

http://www.bloomberg.com/apps/news?pid=20601085&sid=aUJzllXYNSmw&refer=europe
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Sue on 10/14/2006 7:45 AM
Oct 13, 7:02 PM EDT

Congressman Demands Retraction From WSJ

By TIM WHITMIRE
Associated Press Writer

CHARLOTTE, N.C. (AP) -- A congressman in the thick of a tough re-election battle demanded Friday that The Wall Street Journal correct and retract statements in an article that said he slipped projects benefiting his own business interests into the federal budget, a claim he called libelous.

Rep. Charles Taylor said he would sue the newspaper if it does not meet his demands, made in a letter written by Asheville lawyer Robert B. Long Jr. and released by Taylor's office."

http://hosted.ap.org/dynamic/stories/T/TAYLOR_WALL_STREET_JOURNAL?SITE=7219&SECTION=HOME&TEMPLATE=DEFAULT&CTIME=2006-10-13-19-02-24
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By cynabear on 10/14/2006 8:32 AM
While I absolut5ely agree that the issues MUST be pushed through the courts I believe that we also have to educate and give $$$$ to candidates so that they are willing to take the time to educate themselves on this issue, in other words we need a PAC and or a lobbyist.........Also we need a new and better game/clean market/clcean brokerage/banking system,,,remember how revelatory FEDEX was in the begininng......who knew that some other entitiy than the post office could handle mail....we need a fedex for the market....who among us would not keep our money in an online bankinng trading site we knew was free from the fraud that is existing in the system/markets??? I mean i am willing to buy stuff from OSTK when i need stuff but i would be absolutely willing to put my money and buy stks from Otrade or whatever. if they presented themselves as the way to get out of the present system of fraud and corruption......
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Conspiracy Grows on 10/14/2006 8:36 AM
unnamed others- I think if you read this you will realize that a lot more crimes are being committed and ignored until a flashlight get shined. I believe the ignoring of all of these crimes including naked shorting are all interrelated.

Muslim Terror
The Muslim Brotherhood, Nazis and Al-Qaeda
By John Loftus, Jewish Community News 4/10/06

Wednesday, October 11, 2006

(Editor's note: Read it and weep. Weep for joy that John Loftus is there. --Judi McLeod).

I had an unusual education in the Holocaust. When I was working for the Attorney General, I was assigned to do the classified research about the Holocaust, so I went underground to a little town called Suitland, Maryland, right outside Washington, D.C., and that's where the U.S. government buries its secrets -- literally.



http://www.canadafreepress.com/2006/loftus101106.htm

In early March, 2002, I drafted a long lawsuit exposing Professor Sami al-Arian, naming all the crimes he'd committed, all the bombings in Israel, the fundraising in America with terrorism. I mentioned how his money got to him from the Saudis and how the Saudis had convinced our government not to prosecute him for political reasons. Because of my high-level security clearances, everything I write is sort of classified material and has to be sent back to the government before publication, for censorship. So I sent my long lawsuit complaint to the CIA, and they loved it. They said, "Oh, great. We don't like the Saudis either. Go sue them."

Three days later two FBI Agents showed up at my door, saying, "You know, there are only 21 people in the U.S. government that knew some of this information, and now you're 22. How did you find out?" I said, "I'm sorry, I can't tell you, attorney-client privilege." That's why my clients pay me $1.00 each.

The day before I went to file the lawsuit, I got a frantic phone call from the United States Department of Justice. They said, "John, please don't file the lawsuit tomorrow. We really are going to raid these Saudi charities. We're going to close them down. Just give us more time." "Oh yeah, you're going to raid them. That's what you told me in January - - and again in February, and now it's March. You want more time? I'll give you until 4:00 o'clock tomorrow. I'm filing my complaint at 10:00 a.m., so that at 4:00 p.m., I'm going to release the address of the Saudi charities. Back tomorrow. I filed my lawsuit at 10:00 o'clock, and told the press I was going to hold something back for a little bit.

At 10:15, the U.S. government launched Operation Greenquest, a massive raid on all the Saudi charities in homes and businesses, and in one hour we shut down the entire Saudi money-laundering network in America.

From March 20, 2002 to the present, the government has found more and more evidence seized in those archives on that single raid that day. The evidence was so compelling that Professor al-Arian is no longer giving his speeches. He is now in federal prison awaiting trial. His accomplice, Hammoudeh, has also been indicted. Some 32 different people have been indicted in the United States as a direct result of these efforts.

WHY?????????? WHO???????????
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By thelimeyone on 10/14/2006 5:30 PM
Davidn. re your"we need to find a way to share our understanding & knowledge about this crime with the masses" Well i am one of the masses & you are not getting out squat. part 2 of my post yesterday suggested some possible ideas, but i was completely ignored.I would rather be rejected than ignored, it means you aint listening just hearing the sound of your own voices & muttering to yourselves. I am trying very hard on IHUB to get the msg out, but where is the back up?. Also to the person who says only through the courts can we do anything. thats as big a pile of stinkypoo thats coming out of the SEC. do you think the Polish people needed the courts to bring down communism? do you think our govt will not think twice if they try and pass something thats really,really unpopular & causes mass outrage?. all of you need to get the msg out there, aint going to be no groundswell if you dont. action is the only thing that acheives anything, & on a daily basis. each one of us must become our own newspaper/article/messenger or you are going to be forever talking to yourselves. now please disagree with me, something, anything show me your not all comatose.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Just The Facts Please on 10/15/2006 6:13 AM
What would a 1x2 spot on the yahoo message boards cost to say

www.thesanitycheck.com
the truth about wall street

Put it there next to scottrade and etrade etc. and you don't need to run it forever. People will either be curious or they won't.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Little Bo peep on 10/15/2006 6:16 AM
catch this arrow.
Hence the name Thelimeyone.
I did say that I like lime sherbet too.
a small bowl every now and then.
very sweet it is, just like you I bet.

focus only on facts. JUST THE FACTS.

Many rocks still to turn over.
The roaches are scattering, some even changing parties.
The poison is on both sides.

It is tough to run from stinky.

It doesn't much matter if ones computer is hacked and tracked, or the computer burns up in a fire, the mail is taken and/or opened, the list goes on.....

sad part is good people get sucked into the sacks of shit.

Thank goodness for the camera and technology these days.
On me and the sheep 24/7

The threats and scare tactics to shut people down isn't working.

As the verbal arrows stick in our back, the loss of blood,
gives us the strength to chew nails to get to the truth.

We do not allow our mouth to overload our ass.

understand?
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By mhelburn on 10/15/2006 6:48 AM
The letters at the SEC are being placed according to date written and it is difficullt to keep up with ones that are not being posted as they appear.

Orrin Hatch has one, and Larry Thompson has one. I think Larry saw the writing on the wall and had to write something.

http://www.sec.gov/comments/s7-12-06/s71206-267.pdf

http://www.sec.gov/comments/s7-12-06/lethompson8590.pdf

Both of those agree with greater transparency.. 309 letters, most of which, and all the ones from elected officials and regulators, call for transparency, ending grandfathering, reducing MM exemptions.

I am tired of hearing about liquidity. If a person wants a liquid stock, buy a large cap. Let the market decide or the company can do splits. I believe that the liquidity argument is simply a lie to promote manipulation and profits for MM. People should know before they purchase a stock how it trades. They don't need to learn from excessive numbers of counterfeited shares created for the hedge funds by the MM exemption.

It would be interesting to see the volatility and liquidity comparisons of stocks that have options vs. those that don't.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By thelimeyone on 10/15/2006 11:15 AM
Little bo peep. Instead of your obscure cryptic comments how about speaking in plain English. got something on your mind just come out & say it. if you bothered to check my posts on IHUB you will see I am trying to support this cause of ours & I resent your insidious remarks. you ever heard of "constructive criticism". there are always things we can do to improve what we are doing, right now I feel a certain kind of smugness on this blog & thats not good. getting the message to the masses should be of high priority, strike while the iron is hot. sitting back & intellectualising is not the right thing to do right now. IMO we need to get more organised & have aplan of action that we all can in some part be involved. when you start to get the enemy on the run its time to drive home the advantage for a complete rout. 3 weeks from mid term elections is the perfect time to take advantage of their vulnerability. so you or anyone else got some ideas or a plan to get some real momentum going here. I do in fact appreciate everyones efforts so far,but we do need to drive home the advantage. I am not the boogie man, understand?
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By InTheKnow on 10/15/2006 12:06 PM
SETTLE THE TRADES and SETTLE THEM NOW!
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By not the boogie man on 10/15/2006 2:07 PM
Pass this information to all that you know

thesanitycheck.com

and

http://www.petitiononline.com/mrktrfrm/petition.html

to everyone that you know, then the people can decide if they want to join the battle to fix this FRAUD.

http://www.petitiononline.com/mrktrfrm/petition.html
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Niel Storts on 10/12/2006 12:17 PM
No reason to complain because only 82% of the truth was finally acknowledged. This is monumental. I think the market took note of the comments also. Todays trading action was out of normal. We may have witnessed the first half day of semi legitimate behavior on the street. Either that, or the computer running the programmed trades for steve cohen has a worm. We can hope that the miscreants have decided to clean up their act.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By clearthinker on 10/12/2006 12:18 PM
I think the voting issue is bigger than we all know
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By hwh on 10/12/2006 12:19 PM
Without the FED on board you get nothing...hwh
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/12/2006 12:26 PM
I notice they mention the 99% settle stat. If you read the original quote, it says:

"According to the National Securities Clearing Corporation (NSCC), on an average day, approximately 1% (by dollar value) of all trades, including equity, debt, and municipal securities, fail to settle. In other words, 99% (by dollar value) of all trades settle on time."

A minimum of $949.9 trillion of the $1.0806 quadrillion cleared is debt. Actually, a lot more than that is debt as they combine the equity statistics with municpal debt.

Municipal bonds and equity are only $130.7 trillion of the $1.0806 quadrillion.

What is the real number if you only talk percentage of equities that fail and include the pre-netting fails and x-clearing?



Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By broke flat on 10/12/2006 12:28 PM
tommy; there is logic to the NASAA position re options traders. There's an inferred availability of shares when someone sells puts or buys calls (or is it the other way around?). They are guaranteeing to provide shares on demand. Therefore, the naked shares are place-holders for the underlying option. Notice that the NASAA proposal calls for closing out the naked shares upon the earlier of 1) the position being closed or 2) the option expiring. That seems reasonable to me; not perfect. To totally ban the practice as you want is probably attacking 'a bridge too far'.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By davidn on 10/12/2006 12:32 PM
Pre-netting is netting that hides counterfeits from the CNS system. The NSCC is not aware that these counterfeits happened.

1. At the introducing brokerage

Sally counterfeits 1,000 shares and Timmy buys 1,000 shares. The buyer of Sally's shares effectively receives the 1,000 that Timmy bought because the trades net at the level of the brokerage. From the view of the DTCC, Sally didn't sell anything as her trade was masked by Timmy's purchase.

2. At the clearing brokerage

JP Boilerroom countefeits a million shares and Big Bank A buys a million shares. The DTCC is not aware of JP Boilerroom's counterfeit as Big Bank A's purchase masked that trade. All the DTCC sees is the clearing brokerage had no net purchase or sale.

MJK Clearing, Adler Coleman, Refco, etc. are all examples of the second type of pre-netting where the fails were hidden from the NSCC.



Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By mhatmccane on 10/12/2006 1:00 PM
Agreed, a stunning letter. Why the delay in sending the letter? Is it possible it will be ignored because it missed the deadline?
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By bobo on 10/12/2006 1:29 PM
No, it will likely be ignored because Wall Street owns the SEC, and will pay whatever it takes to continue to be allowed to rip off investors with impunity. The deadline is an artifice that has no meaning - it isn't a cutoff, merely a deadline. Sort of like the rules saying don't FTD are rules, but carry no penalties for their violation.

The SEC is masterful at creating meaningful sounding things that actually possess no meaning.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By InTheKnow on 10/12/2006 2:07 PM
Ponzi Schemes in the end fall under their own weight and this one is at the bursting point. Who will be taken down with it?

Who in Congress wants to be a hero and who in Congress wants to feel the wrath of their constituents when they realize how they have been ripped off.
Re: NASAA Comment Letter A Masterpiece - Qualifying the Delivery Failure Problem By Thelimeyone on 10/12/2006 2:09 PM
Re NASAA letter "Improper Incentives" "Uptick Abuses" "We fear that traders may avoid the uptick rule by having another broker enter an accomodating trade for 100 shares at an uptick price, thus permitting the trader to enter an order for a short sale of 100,000 shares".I am an Investor in penny stocks & one thing that keeps coming up is 100 shares traded, which has an almost zero value. Fellow investors on the message boards put this down to a secret code by MM's as 'we need more shares real bad, dont let it go up' or something similiar, the effect is though it kills any upward movement it just previously experienced. Can anyone more knowledgable please advise if this is in anyway related to the NASAA statement?. OT. I follow this site & the stock message boards everyday but IMO there seems to be a huge disconnect between here & pennyland, where NSS is rife. I try to do my bit by providing a link to this site when the subject comes up but rarely do I see anyone doing same. m