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A FOIA Request "Day In The Life Of OSTK" From The SEC

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Posted by:   bobo 2/4/2006 5:37 PM

Alan Newman got his wish today.

Or at least one of his wishes. He asked the SEC for a count of the FTDs in OSTK for August 1, 2005, and was turned down...well, just because. He appealed it, and ultimately received the data.

(NOTE: I went back and looked, and that is not what he asked for - he asked for: "..actual number of shares comprising failed deliveries of shorted stock of Overstock.com (OSTK-Nasdaq) as of August 1, 2005." Now, one reason why there may be quite a bit of confusion and disagreement over what the numbers mean is because I wasn't looking at the actual source document when I wrote the original blog entry - the SEC likely agreed to provide PRECISELY what he asked for, nothing more, or less - the FTDs for SHORTED stock. But what about all the long shares that FTD but weren't marked short? Both domestic as well as international? Are those also in the number? Why would they be? I mean, other than because we would like them to be for a complete answer - why, precisely, would an agency that is very detail oriented and which tends to supply as limited a subset of data as it can, up and volunteer something that wasn't asked for? My hunch is they didn't - they supplied exactly what the request was for.)

Here is the letter that indicated that his request had been granted by the SEC, and here is the FOIA.

The FOIA data reflects a one day snapshot, which aggregates all clearing firm positions, for settlement date 8/1.

550K shares of OSTK, a Reg SHO list company, were failed to deliver as of August 1, 2005.

It appears that this is the cumulative total as of that date, not counting the ex-clearing fails, which experts indicate can be 10X or larger than the "in-system" fails. We are awaiting a definitive confirmation from the SEC on the interpretation of this as a cumulative total.

This should serve as a wake up call to investors, as well as to the apologists for naked short selling, who insist that there is no problem. I'm not sure how large the float is for OSTK, but my hunch is it is maybe 3 million or so...you can do the math on the FTDs from there.

This is the smoking gun. Over 10% of the float are failing - that we know of - the DTCC doesn't tell anyone how large the ex-clearing issue is.

We do not have a final confirmation from the SEC yet, but a prelimimary verbal was that the person spoken to "thought" that it represented the cumulative - he/she is checking to clarify.

As to how we interpret the data, I believe that shows an alarming issue nonetheless - this is a SHO list stock that was just off the list a few months prior to 8/1, so the notion that these could be legal FTDs is an unlikely one, to put it charitably. What we have here is an indication of fraud, IMO - the only question now is how massive a fraud.

I wonder what the FTD information for NFI looks like for April 12-26 2004? Or for the first 2 months of 2005? Want to bet that a lot of the trading in that issue was bogus, designed to act as a bear raid on the stock to force investors to sell, due to margin calls, or panic?

This is it, my friends. The SEC and the DTCC are allowing fraud on a massive scale - the only question now is how massive.

Sure would be nice if the rules mandating prompt clearing and settlement of trades were enforced. And would be even nicer if simple information about the nation's clearing and settlement system wasn't a closely guarded secret. 

Any questions?

 

Copyright ©2006 Bob O'Brien
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Comments (132)
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 6:29 PM
I think that Monday morning, the SEC Counsel's phone is going to be ringing off the hook with requests for more info on this. Call it a hunch...
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Jersey_Devil on 2/4/2006 6:36 PM
Like we didn't already know. They just do not like to provide additional proof and besides that neked shortin is good for us. I am sure the SEC alerted all of their buds on Wall Street that this small piece of proof was being released so that they could cover their butts and raise the noise level in the media. Funny how that has been increasing the last few weeks.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 10:50 PM
Jeff...um...If on one day, the demand for stock exceeds the ability of the bad guys to print shares by 50K...um...er...and the availability is nill...um...the price goes up....

Is this really that hard? The best you have is that on a typical day of manipulation, it inched up, thus the proof is that it had little effect...ignoring that if the 550K hadn't been thrown at the market, it might have increased 10%...are you really that stupid?

Because you don't seem stupid at all to me.

So what do you make of this one day snap shot? Assuming my take on it is correct? Are you going to go down the road of 90% could be legal naked shorts? Or that it is for the good of the Nation?

Please.

Really. Please. Take off the mask for a second and acknowledge that there is a WTF, WTFF quality to this...
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By dan on 2/4/2006 10:56 PM
Jeff, I've been following your posts on SI and appreciate you using your real name. You are a prominent poster in Elgindy's thread (the same guy who shorted the airlines on Sept. 10th and the same guy who was arrested when his CIA buddies were found burnt and hanging upside down from a bridge in Iraq).

It's an honor that you would post here, considering there is no such thing as unsettled trades. Your presence almost endorses the concept.

You seem like an educated reasonable person, with a mission to naked short overvalued companies.

I have two points:

1. Even if a company is overvalued, does that give anyone a reason to take an investor's cash and give them nothing in return. Or worse, to trick them into thinking they received a share? Even if you thought there was a moral reason for this, is it legal? What law allows some do gooder to counterfeit to stop a pump and dump from succeeding?

2. Longs are not always right and sometimes they buy crappy companies. Is it possible that on some rare occassion that naked shorts naked short a good company? How does that play out? What happens if they naked shorted more shares than are available to cover?

Given your timing, it occurred to me that you could be WriterJudd. After all, it is just you and me posting at this time of night. I guess that isn't relevant, but it does give me a chance to remind people to call the SEC and tell them we are pissed that we have proof that we are being screwed.

Folks call http://www.sec.gov/contact/phones.htm and tell them you are appalled that 90% of OSTK trades were counterfeit.

In answer to your question, a common short hedge fund strategy is a combination of long and short.

1. Buy 10% long.

2. Create a short position at the highest buys. Effectively, you create a lid. For example, decide that OSTK will never trade above $30 and infinitely naked short at that level.

3. Use your long shares to whack any bid. It's illegal to short on the bid, so just use a different account in a different country.

4. Slowly lower your infinite volume lid to inevitably lower the share price. As the price falls, the clearing system returns margin, giving more horsepower to short more.










Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By writerjudd on 2/4/2006 10:59 PM
Dan,
Call whomever you want. I'm just suggesting a call to the SEC is a wasted one.

But go ahead. Call like you'd call a wacky FM morning show hoping to be lucky caller #9.

Ask them if their refrigerator is running. Ask if "John" is home.

Have fun with it!

And since I am a friend of Patrick's I'll tell you this: when he has time, he meets with members of Congress, not the SEC. In fact, I appear in a photo, not yet one month old, alongside Patrick and a particularly important US senator (and almost certain future candidate for president), taken following an hour-long meeting in which Patrick walked him through the whole process.

There is no such photo of Patrick and anybody with the SEC. That would be pointless.

But go ahead. Call the SEC and tell the minimum-wage earning woman who answers the phone how mad you are. I'm certain you will make her hate her job even more.

But you won't change anything.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By dan on 2/4/2006 11:08 PM
The fact that Jeff Mitchell is posting here tells me that we have to ALL call the SEC Monday. He is an Elgindy buddy.

http://www.sec.gov/contact/phones.htm

Bobo is incredibly successful. I compare it to snowflakes. You send your letters to regulators and feel you are making no progress. Snowflakes fall and feel like they make no difference.

At some point, some infinitely light snowflake lands and causes an avalanche.

I think we are at this point. If you call the SEC on Monday and ask to understand how they allowed 90% of OSTK trades to be counterfeit, you will be the snowflake that causes the avalanche of change.

He is a major player in the club.

Anthony Elgindy is an Egyptian who paid off the FBI to get insider info on what to short. He naked shorted the airlines on 911, presumably from some tip from the FBI.

His buddies were heavily involved in the CIA in Iraq and he was arrested when he went to the funeral of one of the guys hung upside down from the bridge in Iraq.

The SEC loved him and he ran a site "Anthony Investigations' to help use the "invisible hand" to short pump and dumps. The SEC liked that pump and dumps were being controlled and gave little thought to the constitutionally guaranteed property rights of the investors of the pump and dumps.

http://www.siliconinvestor.com/subject.aspx?subjectid=23993

Since his arrest, others have taken over his thread

http://www.siliconinvestor.com/subject.aspx?subjectid=29007


Too Funny!!! By Jeff Mitchell on 2/4/2006 11:09 PM
The whole reason you guys are making this big issue about naked shorting is because it drives the share price of "innocent" companies into the ground. Dare tell me I'm wrong here. So how can you say with a straight face that when you've "proven" 90% of the volume is from naked shorting that the price didn't get hammered?! Too funny!!!

OK, I've made my point. Bye bye. We now return you to your regularly scheduled programming where what passes for debate are comments like "you are stupid", "WTF", and assorted other invective.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 11:14 PM
Judd. Grace under pressure. Style is everything, and this is but one of the battles you will wage.

I agree that the SEC is as useless as tits on a board. It is a usefull effort to enable everyone to make their own journey of discovery. You are new to the tsunami of inequity we are accustomed to as a tidal flow. It defines this particular adventure, as well as the status quo, for better or for worse.

I also agree that Congress is a better place to focus attention.

But tonight, franky. I am so stunned by all of this that I am going to simply read some David Foster Wallace and hit the lights early - for some things, one can only shake one's rhetorical head in shock, and Jungian shame.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By writerjudd on 2/4/2006 11:18 PM
Bob,
Yes, master. I will try to be more mindful in the future.

But I'm still pissed.

Sleep well,

Judd
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 11:21 PM
Jeff. Babe. Simple. They threw a bunch at it that day. Buyers bought a few more than they threw at it. If you are going to pretend to LOL so resoundingly, perhaps if you acknowledged that on days where demand was 600K and supply was 50K, if they threw 550K at iot the price could go up?

So instead of arguing some straw man, try the facts of this.

How, precisely, in baby language, does that much FTD action on one day reconcile with the notion of a non-manipulated supply and demand aucion markets? Or more specifically, how can a 90% artifical creation of supply be reconciled with a Kindergarten-like euphemism like: "but it went up a few cents, so what is the problem?"

I sense even your own intelligence is insulted by this.

Stop back in anytime.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By writerjudd / Jeff Mitchell on 2/4/2006 11:22 PM
I'm assuming you are full of it, but if Patrick's friend Bobo vouches for you, I will apologize.

In the mean time, I would wonder why big naked shorts like Jeff Mitchell would try to convince us that we shouldn't call the SEC Monday morning.

Most conspiracy sites are not lucky enough to have their would be conspirators pay them a visit.

http://www.sec.gov/contact/phones.htm

For a big gun to fight it tells me they are scared.

Readers, please call the SEC Monday!

You may be shy with nothing to say, but if you make the call, you register as a number. Numbers make policy!




Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 11:23 PM
Judd. Are you wearing a little Barbara Eden ensemble when you say that? Never mind - don't ruin it for us all.

Sleep well yourself. There is always tomorrow...
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By writerjudd on 2/4/2006 11:27 PM
There's no guarantee that was really "Jeff Mitchell"...commenters can use any name they want here. The same way I (writerjudd) had nothing to do with the post timestamped 11:22 (my time) though my name appears in the "By" field alongside the so-called Jeff Mitchell.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 11:29 PM
Ahh. I see. So this could be an imposter? I suppose I will have to turn the approve thing on again, and verify IP's...

So be it. Shame, that.

Good night.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By dan on 2/4/2006 11:30 PM
Bobo, please go to Silicon Investor, look up Jeff Mitchells and realize how successful you are. After Elgindy, he is one of the big guns.

Take it as a compliment that the biggest short is posting here.

I think you are making huge progress and are making someone's life less than comfortable.

One strategy of people like Jeff Mitchell is to change the thread agenda. He isn't going to change mine.

Folks:

1. Call the SEC Monday morning and tell them you are furious to find that 90% of OSTK's trades were counterfeit http://sec.gov/contact/phones.htm

2. Literally send this website to everyone you know. If you have access to a mailing list, send this page to a mailing list.





Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By tom on 2/4/2006 11:36 PM
The OSTK request confirms why I worded my request to avoid individual firm numbers.

I have a request in for PBLS. As long as you do not ask for information by firm, you should get what you ask for. Remember, REG SHO states that the information of individual firm criminal activity is protected.

Is the OSTK number of fails in that day over the 1% of outstanding? Interesting information.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 11:34 PM
Jeff's agenda is sort of immaterial to the actual fact of the FOIA request. It is what it is. If Jeff is honorable, that is to say a legal short, he will celebrate an end to the confusion and the silliness of all the opacity in this issue. If he is an illegal market manipulator, he has a problem in me.

Either way, the outcome will still be what it is.

I don't measure myself by my enemies or my friends. My barometer is internal, and self adjusting.

Good night all.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By writerjudd on 2/4/2006 11:35 PM
Dan,
One more thing before I sign off.

You say "numbers make policy" but please understand: the SEC doesn't make policy, Congress does.

It's the job of the executive branch to carry out (or "execute") the policies created by Congress. Now, that said, I'll concede the fact that for some ponderous reason, the SEC successfully issued Regulation-SHO, an administrative rule, which had the effect of trumping the law. The only thing likely to change that is action by Congress. However they'll do nothing about it until they feel their jobs might depend on it.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By dan on 2/4/2006 11:38 PM
Go to Silicon Investor and search for Jeff Mitchell. Search for Elgindy. I am trying not to be too political, but it is scary stuff.

Any reasonable analysis of the recent posts is Jeff Mitchell is writerjudd, who pretended to be our friend and told us to not phone the SEC on Monday.

Folks, there are a few times in life when the slot machine come up three cherries.

I agree with the poster who noticed that the negative OSTK article coincided with the freedom of information release.

We have a huge nugget here. 90% of trades were FAKE. COUNTERFEITING IS ILLEGAL, YET 90% WERE COUNTERFEIT.

Ignore Jeff Mitchell, call the SEC and send the link to this thread to EVERY email contact you have and encourage them to send it to EVERY contact THEY HAVE.

Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/4/2006 11:44 PM
Dan. Judd is not Jeff Mitchell. That is to say that Writerjudd is not Jeff Mitchell, assuming that this Jeff Mitchell and this Writerjudd are the one and the same we assume that they are.

However, I think that all Judd is saying is that the SEC won't do shit. I agree. They won't. Congress is the answer, or at least the hope.

Having said that, I think we should all call the SEC on Monday - not to say we are pissed, which does nothing, but to find out what the answer to our question is...
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By writerjudd on 2/4/2006 11:45 PM
Hey Bob, you really do need to turn the verification on. All this masquerading is like a bad Love Boat Halloween episode.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By dan on 2/5/2006 12:18 AM
Do you have a way to turn on disclosure of IP addresses? So we can see of two posters are the same person?

Jeff Mitchell is a whale. I'm impressed that you reeled him in. I doubt it is an imposter using his name.

If you have some time, please go through Anthony's posts. When else do you have a chance to read the strategies and stream of consciousness ideas of a short?








Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By gilteddge on 2/5/2006 3:30 AM
..Amazing that the SEC actually provided this information...has the FOIA act finally got them on the ropes..hmmm...interesting
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By adegracia1950 on 2/5/2006 4:11 AM
Jeff,
Your original post suggests that you have some understanding of the issue.
This implies that you are not ignorant or lack knowledge on the issue.
Your post was stupid in the fact that you tried to run a lame excuse for the FTDs in OSTK on 8/1/05 as not being related to naked shorting because the price went up by pennies (price control/containment).
Instead of firing back at the challenges to your post with respect to the coarse or rude responses, how about further elaboration on your statement that it was naked shorting because the share price went up.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By CHRIS on 2/5/2006 5:07 AM
In the call to the SEC Monday make sure they clarify if this is " inclusive of all aged fails, or just the fails for 8/1." some are not taking this as yet unproven (spinned). This needs to be rock solid. imho. It will just be regurgitated again and again until written.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By mhelburn on 2/5/2006 5:39 AM
Why not ask for all of the fails to be posted by the SEC? Rather than burden them with researching individual dates for individual companies, they could post the entire list for each day back to 1990. That would certainly be easier than responding to hundreds of requests and since it is all public information under the FOIA, they need to include it on their site. That would get all of the information for the companies that have been delisted in that time.

Individuals could then do their own research. If they can reveal the information for one day for one company, they can report it all.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Rod Young on 2/5/2006 6:04 AM
Guys before you start screaming at Congressmen, and you should, everybody here has made a basic technical error. Delivery failures on 8-1-05 are for trades from 7-27-05, T+3. The OSTK volume on 7-27-05 was 698,300 shares. Its not 90% of the volume that failed its 78%. If you are going to call Christopher Cox and Richard Shelby criminals they will eat you alive if your facts are flawed.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Ben on 2/5/2006 6:12 AM
If the allegation that this represents just the FTDs for one day, namely Aug. 1, then it is simply outrageous.

People, in particular OSTK shareholders, should be calling their congressman to investigate - particularly ones in looking for some help getting re-elected.

it is time for people to take back their government and throw the complicit crooks at the SEC and Wall Street in jail for years.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By mhelburn on 2/5/2006 6:36 AM
My letter to the SEC


Subject: Freedom of Information
To: chairmanoffice@sec.gov

Dear Sirs,

Alan Newman sent a request number 2005-8081 for information about the aggregate number of fails for OSTK for August 1,2005. His initial request was denied, but his appeal was granted. His letter of October 6,2005 http://thesanitycheck.com/Portals/0/foia013006.pdf was answered on January 30,2006. On August 1,2005 550,185 shares of OSTK failed to deliver.


Four months to respond to a request exhibits a shortage of resources for the Commission. I believe you will be getting more requests, not fewer. To eliminate the burden of responding to individual requests for public information, it would be simpler to create within the SEC website a place where individuals can go to find that information deemed to be public.

Since the aggregate number of fails for OSTK on one date is deemed public information, it follows that all aggregate numbers for all stocks on all dates is public information. It would be beneficial to individuals and the Commission to make this information readily available to the public. Since the SHO list is published everyday and includes all stocks that have reached or exceeded the threshold, and the total number of fails in the various markets are available to the SEC on a daily basis, it would be reasonable to expect that this information should be published daily with the name of the company and the associated fail numbers.

Respectfully,
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 6:39 AM
Rod, you are almost correct. Under trade guidelines, It is Trade plus 3 days for settlement.

July 26 = Trade
July 27, 28, 29 are T+1, T=2, T+3

The first Official day of a FTD for July 26 is August 1. Trade Volume on July 26 was 407,000.

550,000 shares represents 12% of the public float. This number also fails to account for ex-clearing FTD's and wash trades that tempoarily eliminated an FTD in the system. I would love to see this number in Early september when Jack's 200,000 share purchase was in an FTD.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By rtway on 2/5/2006 6:50 AM
When I want to know what time it is I don,t ask what kind or how many gears there are. Just tell me the time. We should all be basking in our victory, however small or large it is. It certainly is a step in the direction we are heading. I myself, will wait to hear from the pros on this subject, Dave Patch, Bob( lot,s of class bunny) O,brien, Bud Berrel, Mark Faulk and the man himself, Dr. Byrne as to what measures or course of action would be most effective, these are the guys that know how many gears are in the watch. Last week I sent a hand written letter and a copy of Bob O,briens list of why NSS is illegal, along with a demand to find out the evidence and the proceedings in the Refco case. I also made mention about the Elgindy case and the FBI agents to further validate the gravity of the case. Besides all that I enclosed a copy of his E-Mail that he sent me responding to my concerns over NSS. In his E-Mail he stated that the gov,t. was already taking care of the problem by using Reg. Sho. With Bob,s excellent article on the illegalities of NSS and Reg. Sho. that will blow apart his E-Mail.I sent this registered mail with receipt request for proof. I maybe have $10 invested, a small price to pay for a noble cause. The Sen. is Barrack Obama it shoul be in his hands Mon. morning, perfect timing.I will be on the phone with the SEC Mon. in the A.M. and also with Sen. Durbin and Shelby and Benet. If they get enough phone calls that tie up their lines, you have made a statement that everybody in the building will hear. That is our purpose, to make them aware we are out here and won,t go away, hell call Bush too.Instead of nitpicking give yourselves a well deserved pat on the back, look how far we have come in such a short time.Hopefully property in the Hamptons will become more readily available. Cramer and Greenberg doing a perp walk with handcuffs would be nirvana.My greatest wish is to see those two in a cell with Bubba, banjo music in the background and their assets liquidated. One can only hope.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By rtway on 2/5/2006 6:58 AM
My apologies Mary, I forgot to include one of the most well versed and dedicated pros, M Helburn. Thanks for the letter.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By InTheKnow on 2/5/2006 7:03 AM
Hey Patchie, you the man!

Settle the trades or settle in jail!
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By mhelburn on 2/5/2006 7:18 AM
rtway,

Don't bandy around that word "pro". I don't get paid for this. It is a labor of love for my country and my kids and for every honest investor. Thanks for including me. I appreciate your efforts also.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Rod Young on 2/5/2006 8:28 AM
Dave (Patchie),

The trade always clears on T+3 not T+3 + 1. Rember I've got 43,000 clearing firm trade records and 3 years worth of CNS reports. I checked to be sure. Trade day is the 27th, T+1 is the 28th, T+2 is the 29th, the 30th is Saturday, the 31st is Sunday, T+3 is the 1st.

I'm not trying to one up anyone. If everyone is going to start yelling on Monday morning you have to get your facts correct. If anyone uses the wrong data you will get your head handed to you.

Nobody seems to be reading these posts deep in this thread, I think a new thread would be appropriate to make sure that everybody has an opportunity to correct a grevious error that will confirm what our detractors always say "we don't know what we are talking about"

I'll send you an email with a trade journal attached so you can confirm it.

Rod



Even if total FTD and not one day, it's still over 8% By other_opinions on 2/5/2006 8:35 AM
According to Nasdaq (http://www.nasdaqtrader.com/asp/short_interest_resp.asp ), the total short interest for July 2006 was 6,530,872 and for August was 6,547,114. So, even if it is total fails, it still means over 8% of the reported short interest (not counting ex-clearing) was naked.

While not as disturbing as 90%, that is still huge! Bobo seems to be making the distinction between aggregate vs. cumulative. However, I'd say look at the phrasing in the original letter. It says "aggregated fails to deliver . . . as of August 1, 2005." I would think that if it were only fails for one day, it would say "ON August 1" not "AS OF August 1."

So, I wouldn't get my hopes too high regarding the fact that this is the total one day fail number. However, I still think it is a smoking gun. Let's say it is the cumulative, then you could still say something like "If all the reported FTDs were to cover, then it would represent 90% of a days trading."

I would also say that Dr. Byrne's reported problem getting delivery of his shares does not jibe with the idea of only 8% FTD. That leaves us with a few possibilities:

1) I'm reading this wrong and it is one day failes, not cumulative.

2) The SEC information is not accurate

3) I'm reading it correct, but the bulk of the fails are ex-clearing and not represented in reported FTD numbers

4) The fact that legally shorted shares can be resold and reshorted means that the FTD isn't that huge, but that most of the shares are phantom and do not have any shareholder rights attached to them.

My suspicion is 3, but even if it is cumulative, I still think it is a smoking gun.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 9:48 AM
My memo to the SEC, NASD, Congress, and the media...



Folks,



Under a FOIA Request, the SEC provided a shareholder of Overstock.com the aggregate fails to deliver in that security for a single trade day last summer. On August 1, 2005 the CNS system had recorded 550,185 shares in aggregate settlement failures for Overstock.com (CUSIP 690370101).



Now 550, 000 shares may seem negligible in nature but it is far from that.



For instance, Overstock.com was trading at a price of $43.00/share on August 1, 2005 and thus 550,000 represents nearly $24 Million in securities sold but not delivered to the purchaser. These 550,000 shares also represents some 12% of the public float, 3% of the shares issued and outstanding, in Overstock.com or 6 times the minimum threshold level required to be listed on the Regulation SHO threshold security list. Overstock.com is trading at 6 times the minimum levels required to be on the threshold security list and that was 8 months after Regulation SHO was first put into place and 5 months after Overstock.com was listed as exceeding the 0.5% threshold. The stock grew 12X from minimum levels in a matter of 4 months. Grew NOT decreased!



So what happened to the price of Overstock.com between April when it was first published on the Regulation SHO threshold security list and August 1 when the stock was trading with 3% settlement failures?



April 2005 Overstock held a reported short position of 5.4 Million shares. In August it was up to 6.5 Million shares even though the stock was trading in excessive settlement failures. This increase in short positions represented a near 33% increase in short position relative to public float. One third of the public float was being additionally shorted when the “past” failures could not yet be settled and those past failures represented a minimum of 3% of the public float.



Also during April 2005 OSTK was trading at slightly more than $40/share and on the last trading day that finally put OSTK on the threshold security list, the stock closed at $42.65 on a trading volume that represented 20% of the public float and resulted in a 1.2% market cap loss for the day. Today, the stock is trading at $23.86 representing a 44% loss in Market Cap since that final trading day in April that put OSTK on the Regulation SHO list.



To make matters worse, the August 1, 2005 FOIA data is exacerbated by the future trading events that demonstrated continued FTD’s trading in the market place. Between August 8, 9 CEO Patrick Byrne purchased 50,000 shares that all resulted in a FTD according to his broker. The purchase price for those 50,000 shares was near $46/share. The FTD’s were eventually delivered as trading plummeted to $36/share some 8 weeks later. Director Jack Byrne also tested the market and purchased 200,000 shares between August 30, 31 for an average price of $40.00/share. Those 200,000 also failed delivery and were eventually delivered some 8 weeks later when the stock price was listed nearly $10.00/share below purchase price. Between purchase price and delivery, Jack Byrne lost nearly $2 Million.



How would these FTD’s that were captured in test purchases become additive to the already excessive 550,000 shares provided by the DTCC? Assuming few of the 550,000 was reduced between August 1 and August 8, 9 would result in a minimum FTD position of 600,000 shares by mid August and nearly 800,000 by early September. Those potential 800,000 FTD’s now representing 23% of the public float and 4.2% of the shares issued and outstanding.



The SEC claims SHO is working but the stock trading and “bear raids” used to cleanse FTD’s for profit would insinuate a different story. It is rumored that firms have allowed FTD’s to persist when shares become available for settlement simply due to the premium made available in the stock lending practice to the short seller. The liability of the FTD is less than the profitability of lending in a hard to locate security. This concept may be explained by the increase from August 2005 to September 2005 of an additional 300,000 short positions and an increase of 1.3 Million short positions between August 2005 and January 2006. Overstock now trading with a reported 7.8 Million shares short or 224% of the public float. Yet Overstock.com is listed daily on the Regulation SHO list and the regulators are taking no steps to reduce that problem during the stock raids.



The SEC may have feared market volatility by forcing the settlement of aged fails but as is indicative of a captured regulator, they have ignored the “bear raid” that has subsequently resulted by the latest rule-making. The Industry we trust to protect our investments has taken on a raiding principle to protect their illegal trading agenda’s.



The data doesn’t lie.



Dave Patch





FOIA Result



http://thesanitycheck.com/Portals/0/foia013006data.pdf



FOIA Memo



http://thesanitycheck.com/Portals/0/foia013006.pdf



Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By browntrout on 2/5/2006 9:58 AM
Patchie- You just sound like an upset shareholder mad because your stock went down instead of up. Oh wait, didn't someone from the SEC already say the samething?
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 10:10 AM
browntrout.. don't own the stock so nothing to be mad about. Nice of you to show concern and nice of you to have the capacity to understand the facts as presented.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By delhiny on 2/5/2006 10:31 AM
Patchie,

I think that was browntrout's attempt at sarcasm. Great memo, BTW, thanks for all you're doing.

CNM
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By AnyWallStreetSettlementsExpertsHere? on 2/5/2006 10:38 AM
What we have here is a positive feedback loop where the conspiracy theorists keep working themselves in a tizzy.

First of all, the 550k shares failing on 8/1/05 ARE indeed a cumulative number. The 550k number also has absolutely nothing to do with trades in the market for OSTK on 8/1/05, or the correct trade date (7/28) for which 8/1 would have been the first settlement date by market convention, T+3. Second, a large portion of any day's trading volume does not involve a change of ownership at the end of the day. Anyone buying and selling a like amount of securities ends up with a pairoff for delivery via the DTCC. So even if someone matched a trade date with its appropriate T+3 settlement date, there is no logical connection between the total trading volume of one versus the other. The fails "datapoint" for 8/1 includes the aged failwhich may or may not clear up over the course of a couple of weeks.

Shares are indeed tough to borrow, for many reasons. There are lots of legal shorts out there...who have borrowed shares, but may need to replace them if the original "loaner" needs them back (sells out.)

So here's some chum for the pool...if on a given day OSTK sees 592k in shares trade, and the day-trading share of this number is 2/3s of the volume (conservative estimate) so that only 200k+/- shares on the day involve a change of ownership...how can 550k shares fail to deliver without the inclusion of aged fails?

And even though the shares are tough to borrow, it appears that smaller order-sized FTDs do indeed clear/settle if given some time. This is consistent with a scenario where large legal shorts squeeze the borrowable supply of shares...not just one with a lot of illegal NSS.

Thoughts, Bobo?






Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Browntrout on 2/5/2006 10:42 AM
Patchie- Now I remember it was Annette Nazareth that said about the same thing as I did. She elaborated by claiming that investors should not have the attitude of believing that there is a “criminal conspiracy when stocks move the wrong way, and the government should do something about it.”
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 10:51 AM
Brownfishbowl...You are correct that that was what Nazareth stated. It was also Nazeterth and her crew of cronies that claimed they needed to grandfather the FTD's because they were afraid of upside market volatility. Aparently downside market volatility is acceptable.

Anywallstreet...I do not disagree with your presumption of shares trading hands in any given day but that does not necessarily add up to real settlement. A market maker could naked short 100,000 shares in a "work the market" strategy and cover 100,000 by the end of the day. They are net zero but, the 100,000 they sold first may fail delivery as the shares received also fail delivery. It is one of the flaws in the net settlement scenario.

Now why not have either of you explain how OSTK is trading according to law under SHO with 550,000 FTD's on Augist 1, 2005. Since all FTD's require guaranteed settlement once on SHO, did OSTK have 550,000 FTD's on that first day it was listed or did it accumulate over time?
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By browntrout on 2/5/2006 10:58 AM
"Now why not have either of you explain how OSTK is trading according to law under SHO with 550,000 FTD's on Augist 1, 2005. Since all FTD's require guaranteed settlement once on SHO, did OSTK have 550,000 FTD's on that first day it was listed or did it accumulate over time?" Maybe it was grandfathered prior to hitting the SHO list?
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By mfairview on 2/5/2006 11:02 AM
Guys, don't forget that NAS sums the counts of the buy AND sell for the volume.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By bobo on 2/5/2006 11:06 AM
Anywallstreetsettlements:

There is netting at the end of the day. There is also the other data points we have - Byrne and family bought almost 300K shares in August and September and not one was delivered on time. Not one. We also have the wording of the letter itself, and what it doesn't say. It doesn't say cumulative. It doesn't say aged. It says aggregate from all clearing sources. It also says as of, rather than on.

So here is what we have: We have a number that is over half a million fails, in a Reg SHO stock, for which there should be few to no FTDs if the rules were being enforced. We do not have precision as to whether that is a one day snapshot, or a cumulative total. We lack that data point.

I'm going to revise the original entry to indicate that there is controversy as to what the numbers mean, and hopefully we will get clarity on that tomorrow. Alan, who got the FOIA, feels that my interpretation is in error. Some experts, who are serious heavy hitters on this topic, feel that my interpretation is the correct one, when taken with all the other available data points - Byrne's lack of ability to get shares delivered, his broker's written admission that there are no legitimate shares trading.

So we don't know. But we will, tomorrow. Hopefully,

My take is that either way we have a smoking gun, as ex-clearing is around 5X-10X larger than the legitimate FTDs. That from a veteran of the clearing and settlement side of the fence, an acknowledged authority on the topic - court-acknowledged as an expert witness.

So if for one day, the real interesting question is "What is the cumulative total of ALL FTDs for OSTK, aggregated from all clearing sources, as of this date."

I think it would be most interesting to find out what the number is as of December - that would be a serious eye-opener.

So either way, this is no small issue. The question of interpretation of the data is a valid one, and one that I freely admit I could have gotten wrong - but there is the nagging "aggregate from clearing sources" info, as well as the lack of specificity in the use of language in these responses - leaving the final question one that only the SEC can answer.

Rod, you are correct on the info you have - but to my mind the distinction between 78% and 90% is meaningless, although you are absolutely right that we need to be accurate. This is a big problem, whichever number is correct, but one is astronomically awful, whereas the other is only somewhat awful.

The impact of CNS and ex-clearing is difficult to assess based on the data we have, but we will have better data over the next few days, I'm sure.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 12:17 PM
I think the answer of whether this FTD data is cumulative vs. a single day is answered by the previous FOIA data we have seen. The language in which this data has been provided is identical to that of the prior NYSE/Nasadq and OTCBB/Pink Sheet data submittals. Those being cumulative totals.

In each case the data is presented as aggregate FTD's as of a date. In this request as well it is stated as aggregate FTD's as of August 1, 2005 representing this to be cumulative. It is this very data that is used to calculate the threshold security listing as this is the cumulative CNS settlement fail data provided to the SEC by the DTCC.

The prior FOIA data requests and language used in the dissemination of data is linked on this site.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By AnyWallStreetSettlementsExpertsHere? on 2/5/2006 12:26 PM
Bobo said:
<<
There is netting at the end of the day. There is also the other data points we have - Byrne and family bought almost 300K shares in August and September and not one was delivered on time. Not one. We also have the wording of the letter itself, and what it doesn't say. It doesn't say cumulative. It doesn't say aged. It says aggregate from all clearing sources. It also says as of, rather than on.

So here is what we have: We have a number that is over half a million fails, in a Reg SHO stock, for which there should be few to no FTDs if the rules were being enforced.>>

You see, this is where we differ. I don't really see it as an abomination if stocks with large short interest take a while to clear large block trades for which multiple borrows must take place before delivery. I would expect delays, and these could be quite long.

Are you in touch with any back-office vets from the Street? I can't get a good answer to my questions (posed elsewhere) about partial delivery. If PB or Pops bought their shares from a market-maker, who may or may not have been long "some" shares, it does not surprise me that a 50k ot 300k block of shares in OSTK would not settle on time. INTC, yes, but OSTK no, due to the tightness in the shares in stock loan. Dealers on the desk tend to leave the delivery issues to the back office. PB's dealer contact saw himself as flat shares, and had to explain to PB why he didn't get delivery of "real" shares in 3, 10, 30 days - requiring back office input. I am suggesting that if for delivery purposes, PB's trade were booked as multiple smaller tickets, he miay have gotten delivery of some shares much earlier...but I need to hear from an honest-to-goodness back office type to confirm my suspicion. I am quite familiar with how OTC bond settlements went pre-central clearing/net settlement. Since equity clearing has a dual structure (DTCC and dealer-dealer) there are different rules that may apply to delivering partials to a client versus a big ticket. So my moniker here is an actual question to which I'm hoping to find a positive response.

AWSSEH

Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 12:34 PM
Anywall street...here is where you and I differ as does the law.

When a stock is listed on reg SHO, ay short sale must have a pre-borrow. FTD's must also be closed within 13 days or mandatory close-out is required. The fact that OSTK seems to have an increasing number of FTD's while a threshold security, and an increasing level of short positions concludes that a problem exists. It is called a bear raid as the excessive sell pressure is causing heartburn for investors and driving them out of the stock.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By AWS on 2/5/2006 12:57 PM
Patchie -

Imagine a world where a security has a large short interest (legal) and relatively small liquid float, and most of the daily trades are in small size. This company is not on the RegSHO list...with no FTDs yet. Let's say the company's president now wants to buy more large blocks of the stock as the price has fallen off, and a previous owner (whose shares were lent out to the shorts) wants to get out. The previous owner in effect sells to the company president and the president converts the shares to physicals. However, a squeeze has occured as one way or another, the "previous owner" needs shares back from the "short" leading to a scramble for borrow. This scenerio repeats itself with other longs (who lent) selling to a non-lending buyer...creating more of a borrow scramble. At some point, fails pile up, and Reg SHO restrictions kick in. If more long (lenders) sell out, fails increase...BUT no NSS actually took place. Shorts who were once legal shorts are now "naked" by virtue of the fact that their borrowed shares were in effect reclaimed.

So it is quite possible for short interest to increase in heavily shorted RegSHO stocks and it not be evidence of a fresh NSS raid.

All you need is a situation whereby long-lenders bail out to a non-lender.

AWS
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By Patchie on 2/5/2006 1:04 PM
AWS...by law, a lender cannot sell until after a loan recall has taken place. This by the words of the SEC.

In the case of OSTK, the FTD's reach unacceptable levels and thus higher restrictions are put into place. OSTK has also seen a continual rise in the reported short interest in the stock while long buyers such as Patrick and Jack buy long and fail delivery.

In August when the FTD's were 550,000 the short interest was 6.5 Million, today it is reported as 7.8 Million, an increase of over 35% of the public float and a level representative now of 224% of the public float. Thus, shorts continue to accumulate as do FTD's and the stock price is taking with these accumulations - the definition of a bear raid.
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By AWS on 2/5/2006 1:05 PM
Patchie/Bobo-

I guess I'm trying to separate as many issues as I can, when many posters here want to bundle everything together. I think that leads to a lot of misunderstanding.

Deliberate NSS is a no-no, bad-dog thing. In my experience on WS, like Whitney Tilson, I've never spoken with anyone who has done it nor have any of them spoken to anyone who has done it. I'm not trying to give it a free hall pass.

I'm trying to inject a bit of reality into the discussion of FTDs. They are not all the byproduct of illegal activity. Jumping to the conclusion that they are muddies all other discussions with regard to OSTK and the PB/JB large block purchases which had persistent fails.

AWS
Re: A FOIA Request "Day In The Life Of OSTK" From The SEC By AWS on 2/5/2006 1:15 PM
<OK. So the lender had the shares out for a term of a month, and now gets them back and is free to sell.

Being short OSTK is a tempting proposition and shares occasionally become borrowable. When the