Why officer stock options don’t count as borrowable shares A valid “locate” under Regulation SHO requires that the broker have reasonable grounds to believe that actual shares can be borrowed and delivered on settlement date.
While it's true that unexercised options aren't "shares," Market Makers (MMs) under Regulation SHO use the existence of these management options as "Locates." They point to the 2020 grant pool and tell the SEC: "There is potential supply here, so we have a 'reasonable belief' we can settle our short sales."
You must like spinning your wheels. If Reg SHO has strong teeth, why is the market a complete circus?
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