Globalnet (fka GLBT)

[fugazyh8er]

From the Webcast I do not hear anything referring to the time frame allowing 6 months to phase in the new amendment addressing covering of NSS positions. This is what I did hear, transcribed below:

http://www.connectlive.com/events/secopenmeetings/

Starting at 26:35 of the Webcast:
After carefully considering the comments we recommend that the commission adopt the amendments to eliminate the grand father provision as proposed. The amendments provide for a 35 day phase in period for previously grand fathered fail to deliver positions in securities that are on the threshold securities list on the effective date of the amendment to allow market participants sufficient time to comply with the new close out requirements; also after considering the comment letters we are recommending that the commission adopt today an amendment to Reg SHO that will extend the close out requirement for fail to deliver resulting from the sale of threshold securities pursuant to the rule 144 of the securities act. Under the amendment such fails to deliver will have to be closed out within 35 rather than 13 settlement days. The recommended amendments also include a technical amendment that will update the market decline limitation in Regulation SHO.

The 6 month time frame that I did hear was in response to commissioner Nazareths' question transcribed below.

Starting at 39:53 of the Webcast:
Could you discuss future plans to post the aggregate fail to deliver data that we receive from the DTC on the commission website. In the near future can you describe how that's going to work and what our reasons were for doing that?

The response mentioning 6 months:

Starting at 41:55 of the Webcast:
There's going to be a 6 month implementation period so that the industry can get its systems together and to be able to address twice a month reporting but we think that's around September. There may be some changes after the elimination of the price tests to brush up references to any one in those rules but I don't think that will delay the implementation period.

I may be wrong but it sounds to me like they have a 35 day phase in period from the effective date of the amendment and 35 days to close out sales from that point forward. Are there any other opinions out there? I would like to understand this thoroughly.