There is nothing to be gleaned from the Daily Reg SHO reports, without the Regulatory Non Tape Transaction reports one cannot determine what is Riskless principle transactions or short for that matter. You have to read SEC Rule 200, which made it a requirement to mark any trade in which the Broker Dealer did not own or expect delivery of shares before settlement as “short”. Doesn’t matter if the party that they traded for is long in the transaction or not:
Converted shares create all kinds of different problems on their own, but you are correct such conversions are often sold short and then reconciled with a large trade less discount on for commission in a single trade. In some cases shares are sold before the conversion has actually taken place, based upon the TA confirming to the broker the shares are in the process of conversion. This sometimes creates Fails To Deliver and results in Reg SHO Flags after so many days of carrying a continuous failure. You often hear that these are “Naked Shorts”, turns out that is quite false, PIPE finances often cause these and if you look under SEC Rule 203 it explains that the position maybe left open up to 35 days before being closed:
Most of what you see on the OTC is DWAC certs that are being sold into the market sometimes before the shares are even in the account of the shareholder. That is of course DTC Eligible securities, but MMs are already making a market based upon these shares and have no need to actually Naked Short a sale when such positions are carried by financiers and dilutive entities. There is no need to when there are an abundance of new shares trying to be sold into the market.
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