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Re: MadDog1313 post# 95898

Monday, 08/19/2013 2:07:50 PM

Monday, August 19, 2013 2:07:50 PM

Post# of 162556
BigBake1 Member Level Tuesday, October 23, 2012 8:07:20 AM
Re: SevenTenEleven post# 31783 Post # of 32793

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CCTC - And the TRUTH will set you free!
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Yes it certainly will and in this case CCTC has no siginificant short positions and even better there are no significant FTDS in this security. These facts show clearly there exist no Abusive Naked Short positions nor even short positions taken against this security. That is the truth supported by the Bi Monthly Short Interest Report and the FTD reports.


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Many times the TRUTH has been posted regarding what the daily short volume numbers actually represent!
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Certainly the ones describing them as meaningless data are in fact correct as it is a snapshot on the intitial trade inception and has nothing to do with actual short positions and or abusive naked short shares. The reason for marking long position trades has been discussed a thousand times and the reason for such marking of trades in accordance with SEC Rule 200 and 203.


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Here is another example of what FINRA has provided to be a likely possibility for how CCTC's short interest vanishes into the dark pools:
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No, FINRA has not provided such a possibility it is clear what their statements pertain to but unfortunately it is being interpreted improperly because of failure to call and discuss with them such terms.


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NITE, through a non-tape transaction, closes out his naked short position with another naked short non-tape transaction, with a counter-party willing to *assume the risk*.
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FALSE, all non tape transactions have a consolidated tape transaction that mirrors the non tape transaction. Both Non Tape and Consolidated tape are in fact reported to FINRA and are reconciled and balanced for accuracy. Non tape transaction are simply transactions that occur during market making that are not reported to the consolidated tape because it would duplicate the trade volume.


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Don't believe me? Just reference FINRA's own information...
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It certainly does not state what you have infered here, in fact it states pretty clearly as to what one can expect when reading such a report. For example you have highlighted they are making it clear that the data does not include every trade. As we all know T-Trades before and after market hours are not included in such reports, due to late reporting. This would cause the numbers to be under inclusive since it is unknown how many of the T-Trades were marked short.

Rule 144 discusses restricted shares, in the OTC many financiers unload such shares and at times do so while the restricted legend is still in place. Using SEC Rule 203 they have up to 35 days to cover those trades and due to using averaged price block trading such trades are in fact always reported after trading hours once the broker has reconciled the total number of shares dumped and the average price of that block sold throughout the trading day.
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7 Transactions may be reported through the Alternative Display Facility (“ADF”), a Trade Reporting Facility (“TRF”), or through the OTC Reporting Facility (“ORF”). The ADF, TRFs and ORF are collectively referred to herein as the “FINRA Facilities.” Trades in certain classes of securities, such as Rule 144A securities, are reported to the ORF, but not disseminated. Non-disseminated securities will not be included in either the daily short sale volume file or the monthly short sale transaction file.

8 Certain OTC transactions (e.g., riskless principal and agency transactions where one member is acting on behalf of another member) are reported to FINRA in related tape and non-tape reports. Tape reports are submitted to FINRA for public dissemination by the appropriate exclusive Securities Information Processor (“SIP”), while non-tape reports are submitted to FINRA, but are not submitted to the SIP for public dissemination. FINRA will not be including non-tape reports in either the daily short sale volume file or the monthly short sale transaction file. Accordingly, in those instances where the short sale indicator is only included in the related non-tape report, the short sale data published in the daily and monthly files may be under-inclusive. Similarly, the published figures will not include odd lots since these transactions are not disseminated to the consolidated tape.


11 While members generally are required to report trades in equity securities to FINRA within 90 seconds, a firm could improperly delay reporting of short sales until well after the close, which would result in the under-reporting of over-the-counter short sale volume. Delaying the reporting of trades for such a purpose would be considered a violation of the applicable trade reporting rules and Rule 2010 (Standards of Commercial Honor and Principles of Trade).
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I am glad I could clear this confusion up for you, anyone can confirm this by simply talking to FINRA about such reports and asking the right questions. The Daily Reg Sho report is meaningless and is simply a settlement tracking tool, they only record the intial leg of a multiple leg trade transaction, such a transaction is clearly defined here:

I have 50,000 shares of CCTC for sale on the best ask, you want 25,000 of those shares. So you place an order with your broker, electronically your brokerage checks internally for shares for sale, but nothing matches the size or price. It is uplined to an ECN where it sits in que. Each broker has an MM quoting for them, your brokers MM sees the order in que and knows I have 50,000 shares for sale at that price.

Electronically it executes an immediate trade to your broker for 25,000 shares sold to your account. In accordance with SEC Rule 200 that trade must be “MARKED” short although it is in fact a long position trade, this is reported to the Daily Reg Sho. At the very same time on a different leg of the same transaction the MM then buys 25,000 shares from my best Ask to cover that open position, this gets reported as a NON TAPE TRANSACTION. This prevents doubling the reported volume of the actual trade that occured. Both consolidated tape and Non Tape Transactions are sent to FINRA and are balanced and reconciled for accuracy.

As you can see clearly in this example for every non tape transaction there is a consolodated matching trade to confirm the market making opportunity. Due to CCTC being a CNS security it is then sent to the DTC and NSCC for clearing and settlement, which results in no human intervention in the trading process from the time it left your keyboard.

Those are the facts.

THE REAL DTCC DISCUSSION

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