Letter: Susanne Trimbath to SEC on Proposed Amendments to Regulation SHO


Susanne Trimbath to SEC on Proposed Amendments to Regulation SHO

Susanne Trimbath

STP Advisory Services, LLC, 29 August 2006

I am a Ph.D. economist doing research and consulting in finance and economics. I am formerly Director of Transfer Agent Services for Depository Trust Company in New York, and Operations Manager for Pacific Depository Trust Company and Pacific Securities Clearing Corporation in San Francisco. I also was Senior Advisor for KPMG on the USAID Capital Markets Project to design and implement trade clearing and settlement operations during privatization in Russia. Over the last three years I have been a paid advisor to companies, investors and law firms on the issues addressed by Regulation SHO. My comments will reflect my expertise in economic analysis of law and market efficiency, plus securities processing operations.

PDF (14 pages): Susanne Trimbath to SEC on Proposed Amendments to Regulation SHO

Article: Naked Justice?

Article - Media, Publications

Naked Justice?

Liz Moyer, 29 August 2006

Louisiana State Attorney General Charles Foti is trying to force UBS, the Wall Street investment bank, to turn over vast quantities of information on its trading, stock lending and other activities related to shares of software firm Sedona.

The Louisiana Department of Justice filed documents in a state court Tuesday to compel UBS to hand over the information in ten days.

The state is probing naked short-selling, which is the practice of selling shares short without borrowing them. It is an issue that has already been raised in reference to Sedona Sedona. in an ongoing civil lawsuit against a number of brokers and hedge funds and in a Securities and Exchange Commission federal court case filed in April in New York against one brokerage and several individuals. Continue reading “Article: Naked Justice?”

Article: Naked [Short Selling] Horror


Naked Horror

Liz Moyer

Forbes, 25 August 2006

Suspicious trading last year in shares of Global Links, a small Nevada real estate holding company, was far more intense than previously thought.

Data released to Patch earlier this month had shown trade fails of 10 million shares starting in mid-April, a time when 4 million shares of Global Links were issued and outstanding.

Web: Lies, Invention, Journalists, and the SEC


Lies, Invention, Journalists, and the SEC

Bob O’Brien

Yahoo as cited by Sanity Check via Wayback, 21 August 2006

The subject matter, Mark Cuban’s ill-conceived stock bashing website that’s nothing more than a foil to slam his short positions, is the ostensible topic. I haven’t even bothered commenting on the site, as it’s pretty obvious to most upright bipeds what is being done there.

But this article is astounding – I literally thought that the guy who emailed me the link was making it up.

Access archived page.


Web: NY Press Dead Silent on SEC Cover-Up, Except For Forbes’ Liz Moyer


NY Press Dead Silent on SEC Cover-Up, Except For Forbes’ Liz Moyer

Bob O’Brien

Sanity Check, 21 August 2006

Maybe if we don’t talk about the SEC cover-up, it never happened?

That seems to be the way our venerated NY press corps is treating the FOIA data on Global Links – the topic of the last two blogs, and of a Forbes article on Friday.

This is playing out like the Dan Rather incident, but times ten. Bloggers and a few mainstream pubs get it and break the story, while the media circles its wagons and goes into denial mode.

Anyone surprised? Note that there is nothing from the WSJ, nothing from the NY Times, nothing from Barron’s, nothing from the NY Sun, nothing from TheStreet.com or Marketwatch, nothing from CNBC, nor Bloomberg, nor AP, nor Reuters…not even from the Post.

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Memorandum: Fails to Deliver Pre- and Post-Regulation SHO


Fails to Deliver Pre- and Post-Regulation SHO

21 August 2006

Office of Economic Analysis

This memorandum provides summary data on fails to deliver through May 2006. It examines fails to deliver before and after the implementation of the Rule 203 of Regulation SHO. The data, as reported by NSCC, cover all stocks with aggregate fails to deliver of 10,000 shares or more.

PDF (6 pages): Fails to Deliver Pre- and Post-Regulation SHO

Article: ‘Not MY Stock’: The Latest Way To Fight Shorts

Article - Media

‘Not MY Stock’: The Latest Way To Fight Shorts

Kara Scannell

The Wall Street Journal, 2 August 2006

Some executives are reaching for an odd tactic in an expanding battle against short sellers, who profit when share prices fall.

The executives — at smaller companies that often don’t trade on big exchanges — are pushing shareholders to lock away their physical stock certificates so the short sellers can’t get their hands on the shares.

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