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janice shell

03/28/19 5:38 PM

#285822 RE: op9171787 #285821

Newsflash: Without fails to deliver, there's no NSS. And fails to deliver are not reported by the people who fail to deliver stock bought or sold.

Get it? Fails ARE reported. And if there're enough of them, the stock makes the Reg SHO Threshold List, which I just linked here. BBDA is not on the list, and never has been.

Like nearly all OTC issues, BBDA hasn't been shorted heavily. Here again is what Cromwell Coulson had to say about that not long ago:

MR. COULSON: Great. So at OTC Markets, we despise fraud. I mean, fraud makes markets not work. It puts your thumb on the scale, fraud and manipulation. Most of the time, you can have markets handle that. But as the Chair said, in microcap securities on exchanges in the OTC market, there's less liquidity, there's less active trading. You know, there's also a lot less short selling. While Tesla can see 25 percent of its market cap sold short, the most sold short stocks OTC is 5 percent and the average illiquid OTC security is less than 1 percent of its shares sold short, and that's from Reg SHO. So there are -- there's more volatility here.

And Coulson is absolutely right. Shorty is just not a convincing scapegoat in the OTC.

https://www.sec.gov/spotlight/equity-market-structure-roundtables/retail-fraud-round-roundtable-092618-transcript.pdf