The true magnitude of FTDs is obscured by Continuous Net Settlement (CNS), which nets failures against shares held at DTCC.18 The DTCC’s Stock Borrow Program (SBP) further obscures the truth. Furthermore, the statistics above omit "ex-clearing" —that is, trades cleared directly by brokers bypassing the DTCC. Ex-clearing trades are exempt from the reporting requirements of Regulation SHO.” FTDs in ex-clearing are likely many times larger than the quantities discussed above.
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