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patchman

07/27/10 2:36 PM

#38656 RE: Papalaka #38607

From: "SPR" <spr@dtcc.com>
To: idpatch@comcast.net
Cc: "SPR" <spr@dtcc.com>
Sent: Tuesday, July 27, 2010 2:32:13 PM
Subject: Re: SPR Report Accuracy


The only information reported in an SPR are the shares held in Cede and Co's name by brokerage house/bank (our participants).


idpatch@comcast.net
07/26/2010 11:36 AM
To SPR/DTCC@DTCC
cc
Subject SPR Report Accuracy








To whom it may concern,

In a corporate filing and press release Bederra Corporation made the following claim:

Regulation SHO data and Buyins.net have indicated the presence of large, detrimental accumulated short positions, and a NOBO (Non-Objecting Beneficial Owner) list of shareholders dated April 27, 2010 for the company revealed approximately 1 billion shares in excess of the company's actual public float at that time. An SPR (Securities Position Report) from DTCC dated May 28, 2010 reflects a 1.1 billion-share excess in the number of shares held at brokerages.

I am interested in how the SPR report can report such an excess in shares? Does the DTCC report out inventory that exceeds the quantity of shares held in the name of Cede and Co or would the SPR report only report out shares transferred to accounts that are aligned and backed with a physical certificate? At the time of this release, there were relatively few fails to deliver in this market and a very low short position reported in the stock.

Could somebody shed some light on the claims being made by this company or if such claims could ever truly exist? I would think that the SPR would only report out on an inventory count that the DTCC could support with shares.

Thanks,

Dave Patch


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