GNCP - Or T35...
An FTD is only created when the market maker is required to deliver that which he has not located.
Self-clearing and self-settlement, along with simply generating an electronic equity entitlement within a closed system (retail client account, retail broker, market maker, counter party assuming risk) allows for the fraud to be perpetuated.
Add to this failure to properly report blue sheet data to the SEC, and viola, the perfect crime occurs day in and day out.
Tic Toc