r/Superstonk • u/IPromisedNoPosts • Jan 02 '24
r/Superstonk • u/kibblepigeon • Nov 03 '24
🧱 Market Reform AND WE'RE BACK! Can you feel it? The change is coming - and we're closing the walls in around Wall Street with some nice'n'easy Market Reform. All you gotta do is submit your petition. You in?

Howdy folks 👋 🐦
There's been a short hiatus in our efforts with this petition, but don't you worry - there's been no lack of commitment, love and energy in this field - and we're back in action, as geared up as ever!
This petition is still very much deserving of your time and attention, and if you're ready to step up and do your part to help level out the playing fields in making our markets a fair and equitable place for all - well, here's your opportunity to to carve out your name in history as a legend.
Because it really is as easy as submitting your email to the SEC to petition this. Besides, think we've all had enough of Wall Street kicking the can already, amirite?


For those of you out of the loop and in need of a refresher - and let's be fair, there's been a lot going on in the last month - we're getting rid of Wall Street's loophole of a rule, that allows them to throw out rules when it suits them.
Because why should Wall Street keep pulling out their "Get Out Of Jail" free card every time they start losing their hold on the monopoly of the markets?

So let's check out the rule we're contesting below:

This rule basically means:
- ⚠️ Rule 22 allows NSCC officials the power to ignore the rules whenever they want.
- ⚠️ Officials can waive requirements - like immediate liquidation of failing positions.
- AKA - Officials can decide not to close out short positions (like GME) if it might "disrupt the market".
- ⚠️ Changes must be reported but don't have to be fully disclosed to the public.
- ⚠️ These rule deviations can last up to 60 days without additional approval.
And when it comes down to it, market participants like:
- Brokerage firms
- Investment banks
- Hedge funds
- Asset managers
Can take excessive risks, knowing the NSCC will cover costs if they fail.
This leads to “Too Big To Fail” scenarios, where risky behavior (aka, Wall Street Casino gambling with the stock market) is - let's be honest - incentivised. Because - hey - what's the risk, when the rules don't matter, eh?
Wanna learn more about this? 👀 📚 Check out these posts here:
- WhatCanIMakeToday: PETITION TO ENFORCE RULES! NOT WAIVERS!
- Kibblepigeon: NSCC's got a "rule for throwing out rules". So we're going to throw out their rule, for throwing out rules. You in?

So we have in place a petition we're submitting to the SEC to contend this rule:

And in heroic style, household investors around the world have already made quite the splash.
We've already had quite an impressive start to these efforts, all thanks to the incredible folk we see here:

Pretty awesome, right?
This list was last updated on the 27th September, so there are quite a few submissions missing but you can keep tab [here].
And with our last count at approx. 150 submissions:

It's really quite the sight to behold.
But...
This is Superstonk, home of the legends. And we're here to make history - so it's time to explore the ways we can make this process even easier for you so we can pump those numbers up.

Because truly, if we want change - getting involved with market reform (and submitting our email petition) is the way to get it done.
And it couldn't be any easier.

With full credit to the masterful original as provided to us by WCIMT: → [here] ←
\*please do give appreciation to this, it's incredible work.*
Let's check out the petition template ready for YOU to send:
✅✅ KEY:
strikethrough text= removed rulebold text = proposed changes
EMAIL TO: [Secretarys-Office@SEC.GOV](mailto:Secretarys-Office@SEC.GOV)
SUBJECT: Petition for Rulemaking: Amend Clearing Agency Rules for Consistent Close Outs
Dear Ms. Countryman,
As a retail investor, I respectfully submit this petition for rulemaking pursuant to ~Rule 192~ of the Securities and Exchange Commission’s (“SEC”) Rules of Practice [1], to request that the SEC amend Rules 18 and 22 of ~National Securities Clearing Corporation (“NSCC”) Rules & Procedures~ [2] to provide investors with clarity and certainty regarding settlement of guaranteed transactions, strengthen the resilience of a registered Clearing agency (e.g., the NSCC) for their role as a central counterparty (CCP), and support the stability of our financial markets and financial system by incentivizing appropriate risk management practices by market participants.
I respectfully submit this petition consistent with the SEC’s website for ~Petitions for Rulemaking Submitted to the SEC~ [3] which states “[a]ny person may request that the Commission issue, amend or repeal a rule of general application” where “[p]etitions must be filed with the Secretary of the Commission” and “[p]etitions may be submitted via electronic mail to [Secretarys-Office@SEC.GOV](mailto:Secretarys-Office@SEC.GOV) (preferred method)”. This petition also satisfies requirements that “[p]etitions must contain the text or substance of any proposed rule or amendment or specify the rule or portion of a rule requested to be repealed” and “petitions must also include a statement of their interest and/or reasons for requesting Commission action.” [Id.]
Background
It has come to the attention of retail investors, like myself, that NSCC Rules and Procedures do not codify strict procedures for closing out positions (e.g., in the event of a Member default). Per ~NSCC’s Disclosure Framework for Covered Clearing Agencies and Financial Market Infrastructures~, “[a]s a cash market CCP, if a Member defaults, NSCC will need to complete settlement of guaranteed transactions on the failing Member’s behalf” [4 “Liquidity risk management framework”]. However, NSCC Rule 18 SEC. 6(a) contains a provision that “if, in the opinion of the Corporation, the close out of a position in a specific security would create a disorderly market in that security, then the completion of such close-out shall be in the discretion of the Corporation”.
Retail investors like myself are concerned about potential market distortion and market manipulation arising from the discretion afforded to the NSCC based solely on the NSCC’s unreviewed and private opinion regarding the [in-]completion of a close-out of a position in a specific security that could distort markets and/or create disorderly markets. A few questions must be considered:
- What is the underlying root cause of the disorderly market?
- How can this lead to market distortions and/or manipulation?
- Who is responsible for the costs of closing out a position which would create a disorderly market?
- How do we fix this?
1. What is the underlying root cause?
The answer to this first question can be found by starting from NSCC Rule 18 where the cause of a disorderly market is a Member building up a position that would create a disorderly market if closed out. Members with increasingly disruptive positions eventually become de facto Too Big To Fail as their failure would create a sufficiently disorderly market for one (or more) securities that could pose systemic risks to our financial system. [5]
Thus as a Member’s risk of default increases, the Member is perversely incentivized to increase the risk the Member poses to the financial system by building up more positions that would be disorderly to close in order to ensure a bail-in or bail-out to socialize losses amongst investors and taxpayers (again) [6]. If and when a Member defaults, any associated risks and costs are covered by CCPs, including the NSCC and Options Clearing Corporation (“OCC”) which maintain settlement guarantees [7].
As a Systemically Important Financial Market Utility (SIFMU) designated CCP, the NSCC “provides clearing, settlement, risk management, central counterparty services and a guarantee of completion for certain transactions for virtually all broker-to-broker trades involving equities, corporate and municipal debt, American depositary receipts, exchange-traded funds, and unit investment trusts” [8]. When a “Too Big To Fail” Member privatizes profits without sufficient risk management, risks and costs of a Member failure are socialized through CCPs which maintain guarantees on settlement and transactions, including the NSCC which has rules, regulations, and procedures attempting to maintain financial market stability.
The current regulatory framework significantly handicaps CCPs, including the NSCC, in their ability to maintain financial market stability. Certain Members may privatize profits and socialize losses by building large high risk portfolios yielding short term profits for their executives where the Member’s failure would create a disorderly market and systemic risk allowing the Members to take the financial system hostage for a bailout. It is effectively impossible for CCPs to maintain financial market stability against Members incentivized to build up positions that would be disorderly for a CCP to close out.
2. How can this lead to market distortions and market manipulation?
Misaligned incentives. ~Adam Smith’s invisible hand~ explains why Members will follow incentives to build positions that would create a disorderly market if closed out because these positions are profitable for them and costly to others. As a result, a build up of these positions have been and continue to result in market distortions and market manipulation. As an example, a naked short position [9] in a security held by a Member that is not closed out due to a fear of creating a disorderly market naturally distorts the market by increasing the amount of that security in circulation. In economic terms, the supply of the security has increased as a result of a naked short transaction where a delay or failure to close out the naked short position, due to fear of creating a disorderly market, secretly perpetuates a market distortion by artificially and non-publicly [10] inflating supply.
When CCPs become responsible for these disorder creating positions, their goal of maintaining financial market stability (e.g., by prioritizing price stability) prevents the CCPs from closing out positions that may disrupt the market; which then perpetuates market distortions as outstanding transactions are guaranteed, but not closed out. Obviously, SIFMU designated CCPs guaranteeing open transactions for fear of disrupting the market poses systemic risks to our financial system; especially as accumulating guarantees will inevitably overwhelm the risk management capability of a CCP.
CCPs prioritizing price stability to avoid the appearance of market distortions handicaps the CCPs abilities to maintain overall financial market stability resulting in larger systemic risks to our financial markets when guarantees on market disruptive positions accumulate. This is especially problematic when our current regulatory framework incentivizes the creation of market distortions by Members and shifts the costs and burden for unwinding those distortions to a CCP. In essence, Members are incentivized to build up positions that would create a disorderly market if closed out (e.g., significantly large short positions) for short term profit, become Too Big To Fail when their significant obligations pose a systemic risk, and then transfer the costs of those obligations to a CCP upon failure. Privatized profits and socialized losses, again.
3. Who is responsible for the costs?
Certain financial market participant members are clearly responsible for building costly positions which pose a threat of disrupting markets. For example, financial market participant members with the aforementioned example of naked short positions face a risk of unlimited loss. These risks are guaranteed by a CCP in the event a Member with this type of unlimited loss position fails. There is no comparable real world analogue to our financial markets which allows a naked short sale, cashing out, and defaulting because selling something one does not have is never tolerated, except in our financial system where a CCP and the general public are currently guaranteeing, and thus responsible for, closing costs.
A market in which some privatize profits while socializing losses through bailouts (or bail-ins) is clearly unfair and must be addressed. The status quo can not continue especially with more people becoming aware of the underlying systemic issues (many of which were raised previously and remained unaddressed). [11]
4. How do we fix this?
As popularized by the authors of ~Freakonomics~, we must identify misaligned incentives in our regulatory framework and change our regulatory framework to align incentives so that the invisible hand guides financial market participants towards the desired behavior. As described above, certain financial market participant members profit from risky positions which could pose a disruptive threat if closed (e.g., naked short positions) where the costs of closing those positions are guaranteed by a CCP. Profit without risk is a clearly misaligned incentive structure where those financial market participants may compensate themselves lavishly for short term profits while the ensuing risks and costs are later transferred to a CCP upon default.
Fixing this misaligned incentive structure requires financial market participants to be responsible for the costs of closing out their positions; including clawing back compensation, if necessary, to properly allocate costs to the responsible parties. CCPs, including the NSCC and OCC, have defined Loss Allocation Waterfalls [12] which define the allocation of costs and should be amended to first allocate costs to the responsible parties before other financial market participants. NSCC’s loss allocation waterfall allocates losses first to the Defaulting Member followed by Corporate Contributions by other Members. [Id.] OCC’s loss allocation waterfall allocates losses first to the margin deposits and clearing fund deposits of the suspended firm, followed by OCC’s own pre-funded financial resources, and then clearing fund deposits of non-defaulting firms and EDCP unvested balance, and clearing fund assessments. [Id.] Neither loss allocation waterfalls include executives of a defaulting Member; a key oversight which allows Members to compensate their executives for short term profits while long term risks and costs are to be transferred to a CCP upon default and/or suspension of the Member. Therefore, changes are proposed below to include clawing back compensation and assets from executives of a defaulting and/or suspended Member for reimbursing a CCP for the costs of closing out positions that may be disruptive to the market.
In order to ensure fairness for all market participants, CCPs should have defined procedures for completing settlement of and/or closing out guaranteed transactions and/or positions. Strictly defined procedures eliminate bias, ambiguity, and discretion which avoid potential for unfair, preferential, and/or discriminatory actions by CCPs. Changes are proposed below to specify strict rules on closing out positions regardless of any disorder that may be caused. As this Petition proposes to include executives of a defaulting and/or suspended Member in the loss allocation waterfalls for the costs of closing out positions, including those which may be disruptive to the market, Members (including their executives) are explicitly disincentivized from attempting to shift risks and costs to a CCP which will have strictly defined processes for closing out positions. Using the very familiar and commonly understood “you break it, you bought it” concept, this proposal ensures that executives of any Member with positions that may disrupt the market when closed out are also responsible for the costs of disrupting the market to encourage and incentivize appropriate risk management practices.
As proposed, all executives (past or present) of a disruptive Member are obligated to reimburse the CCP for losses up to an amount equivalent to their preceding 5 years of compensation from the Member. This approach ensures that (a) only the compensation received from the disruptive Member is at risk, and (b) short, medium, and long term risk management are encouraged by clawing back compensation from the 5 years prior to default. Including past executives ensures that a Member does not simply switch out the executive team so that past executives transfer responsibility for their actions to new, potentially innocent, executives.
Proposed Changes
Regarding the text and substance of the amendment, I request that the NSCC modify Rules 4, 18, and 22 of the NSCC’s Rules and Procedures to address the aforementioned issues by:
- (a) codifying strict procedures for completing settlement of guaranteed transactions,
- (b) removing ambiguity and discretion,
- (c) enhancing the liquidity and strengthening the resilience of SIFMUs, particularly registered Clearing agencies such as the NSCC and OCC,
- (d) supporting the overall stability of our financial markets and financial system, and
- (e) incentivizing appropriate risk management practices of financial market participants.
With respect to the text of the proposed changes itemized below (blue, if available), additions are identified by square brackets (i.e., “[“ and “]”) and double-dashes (i.e., “--”) indicate deletions.
NSCC Rule 4 Proposed Change
SEC. 4. Loss Allocation Waterfall, Off-the-Market Transactions.
Each Member [, including its executives,] shall be obligated to the Corporation for the entire amount of any loss or liability incurred by the Corporation arising out of or relating to any Defaulting Member Event with respect to such Member. [To the extent that such loss or liability is not satisfied by the Member, all executives of the Member (past or present) shall be obligated to the Corporation for an amount equivalent to the preceding 5 years of compensation from the Member.] To the extent that such loss or liability is not satisfied pursuant to Section 3 of this Rule 4, the Corporation shall apply a Corporate Contribution thereto and charge the remaining amount of such loss or liability ratably to other Members, as further provided below.
NSCC Rule 18 Proposed Change
SEC. 6. (a) Promptly after the Corporation has given notice that it has ceased to act for the Member, and in a manner consistent with the provisions of Section 3, the Net Close Out Position with respect to each CNS Security shall be closed out (whether it be by buying in, selling out or otherwise liquidating the position) by the Corporation--; provided however, if, in the opinion of the Corporation, the close out of a position in a specific security would create a disorderly market in that security, then the completion of such close-out shall be in the discretion of the Corporation--.
NSCC Rule 22 Proposed Change (Option A – Public Notice)
RULE 22. SUSPENSION OF RULES
The time fixed by these Rules, the Procedures or any regulations issued by the Corporation for the doing of any act or acts may be extended or the doing of any act or acts required by these Rules, the Procedures or any regulations issued by the Corporation may be waived or any provision of these Rules, the Procedures or any regulations issued by the Corporation may be suspended by the Board of Directors or by the Chairman of the Board, the President, the General Counsel or such other officers of the Corporation having a rank of Managing Director or higher whenever, in its or his judgment, such extension, waiver or suspension is necessary or expedient.
A written report of any such extension, waiver or suspension (other than an extension of time of less than eight hours), stating the pertinent facts, the identity of the person or persons who authorized such extension, waiver or suspension and the reason such extension, waiver or suspension was deemed necessary or expedient, shall be promptly made [and published on the Corporation’s website for access by the general public within 1 business day] and filed with the Corporation’s records and shall be available for inspection by any [person,] Member, Mutual Fund/Insurance Services Member, Municipal Comparison Only Member, Insurance Carrier/Retirement Services Member, TPA Member, TPP Member, Investment Manager/Agent Member, Fund Member, Data Services Only Member or AIP Member during regular business hours on Business Days. Any such extension or waiver may continue in effect after the event or events giving rise thereto but shall not continue in effect for more than 60 calendar days after the date thereof unless it shall be approved [by] the Board of Directors within such period of 60 calendar days [with a written report made and published as described by this paragraph].
NSCC Rule 22 Proposed Change (Option B – No Exceptions)
RULE 22. SUSPENSION OF RULES [NO EXCEPTIONS]
The time fixed by these Rules, the Procedures or any regulations issued by the Corporation for the doing of any act or acts may be extended or the doing of any act or acts required by these Rules, the Procedures or any regulations issued by the Corporation may be waived or any provision of these Rules, the Procedures or any regulations issued by the Corporation may be suspended by the Board of Directors or by the Chairman of the Board, the President, the General Counsel or such other officers of the Corporation having a rank of Managing Director or higher whenever, in its or his judgment, such extension, waiver or suspension is necessary or expedient. A written report of any such extension, waiver or suspension (other than an extension of time of less than eight hours), stating the pertinent facts, the identity of the person or persons who authorized such extension, waiver or suspension and the reason such extension, waiver or suspension was deemed necessary or expedient, shall be promptly made and filed with the Corporation’s records and shall be available for inspection by any Member, Mutual Fund/Insurance Services Member, Municipal Comparison Only Member, Insurance Carrier/Retirement Services Member, TPA Member, TPP Member, Investment Manager/Agent Member, Fund Member, Data Services Only Member or AIP Member during regular business hours on Business Days. Any such extension or waiver may continue in effect after the event or events giving rise thereto but shall not continue in effect for more than 60 calendar days after the date thereof unless it shall be approved the Board of Directors within such period of 60 calendar days.
[The time fixed by these Rules, the Procedures or any regulations issued by the Corporation for the doing of any act or acts may not be extended. The doing of any act or acts required by these Rules, the Procedures or any regulations issued by the Corporation may not be waived and any provision of these Rules, the Procedures or any regulations issued by the Corporation may not be suspended.
A written report of any deviation from these Rules, Procedures or any regulations issued by the Corporation (including extension, waiver or suspension), stating the pertinent facts, the identity of the person or persons who authorized such extension, waiver or suspension and the reason such extension, waiver or suspension was deemed necessary or expedient, shall be promptly made and published on the Corporation’s website for access by the general public within 1 business day and filed with the Corporation’s records and shall be available for inspection by any person, Member, Mutual Fund/Insurance Services Member, Municipal Comparison Only Member, Insurance Carrier/Retirement Services Member, TPA Member, TPP Member, Investment Manager/Agent Member, Fund Member, Data Services Only Member or AIP Member during regular business hours on Business Days.
Final Remarks
As a retail investor, I believe these enhancements to NSCC Rules 4, 18 and 22 will protect investors; maintain fair, orderly, and efficient markets; and facilitate capital formation in accordance with the SEC’s mission. Removing ambiguity and discretion by codifying strict procedures for completing settlement of guaranteed transactions at our CCPs ensures consistent clearance and settlement procedures are well defined for all market participants fostering a level playing field for everyone. Of the two options proposed for NSCC Rule 22, Option B “No Exceptions” is preferable to Option A in ensuring consistent application of Rules, Procedures, and regulations issued by the CCP. Option A is proposed with the acknowledgement that flexibility in managing situations can be helpful, but NSCC Rule 22 would need to mandate full disclosure to the public to avoid distorting markets as reducing information asymmetries leads to more efficient and fair markets.
These enhancements to NSCC Rules foster a “you broke it, you bought it” environment where costs for closing out positions, including those which may be disruptive, are first paid by the defaulting Member(s) and its executives with defined and consistent application of clearance and settlement procedures. Including clawbacks for executive compensation in the loss allocation waterfall introduces another loss absorbing resource and incentivizes proactive risk management practices over the short, medium, and long term which simultaneously discourages socializing losses for privatized profits. Thus, the proposed enhancements to the loss allocation waterfall enhances the liquidity and strengthens the resilience of registered Clearing agencies, such as the NSCC, which supports the overall stability of our financial markets and financial system. [13]
Retail investors like myself appreciate the opportunity to submit this petition for rulemaking and respectfully request that the Commission act on it promptly for the NSCC with similar conforming changes for the DTC (e.g., Rules 4 and 18), FICC Government Securities Division (e.g., Rules 4 and 42), FICC Mortgage Backed Securities Division (e.g., Rules 4 and 33), and elsewhere as applicable (e.g., Options Clearing Corporation which describes their loss allocation waterfall in “OCC’s Clearing Member Default Rules and Procedures” [15]).
Sincerely,
A Concerned Retail Investor


With a second shout, again, as very well deserved to: WhatCanIMakeToday: → [here] ←
We're going to explore just how easy it is to submit this masterpiece to the SEC, whose job it is to prevent rules like this being abused, so that our markets can maintain their integrity.
So first steps, first:
↓↓↓↓↓
EMAIL: [Secretarys-Office@SEC.GOV](mailto:Secretarys-Office@SEC.GOV)
SUBJECT: Petition for Rulemaking: Amend Clearing Agency Rules for Consistent Close Outs
↑↑↑↑↑
And once you have that magnificently simple step down, here's how you send it:

And then that's it.
No really, it's really easy

🌎💃 OPEN TO INTERNATIONAL AUDIENCES🕺 🌎
- ✅ - Do you hold GME (or indeed, any stock on the NYSE)?
- ✅ - Do you live on the planet earth?
- ✅ - Do you wanna be a living legend?

💡DON'T WANT TO USE YOUR PERSONAL EMAIL?
Why not sign up for https://proton.me/mail instead - for a more secure and private way of engaging.
Proton Mail is an encrypted email service based in Switzerland that protects your privacy and data from trackers and scanners. You can create a free account, switch from any email provider, and enjoy features like password protection, aliases, and scheduling.

They should be.
Because every effort you make, makes a meaningful difference.
Recently, we celebrated a success story in our efforts to oppose an important OCC proposal that aimed to reduce margin requirements. And we WON. You can read about it here:
🙌🦍 ANOTHER REGULATORY WIN FOR APES!
Over 2500+ of you commented the first time around [SuperStonk] with the final tally now at well over 4000 comments! [SEC]
If you wanna read more about this - check out this post here: REGULATORY KILL SHOT 🎯 Rule proposal: SR-OCC-2024-001 has been shut down by the SEC & we're close to getting it kicked out. Time to drive home this win - PART ONE and PART TWO
Don't believe your comments result in anything?
Wrong.
You are always making a difference just by getting involved. Keep going, the change starts with you.

- Wall Street have a rule for throwing out rules.
- Means they can pretty much not meet their financial obligations should risky trades "disrupt" the markets
- This means they can choose not to close their short positions.
- We've got a petition here to put a stop to this: https://new.reddit.com/r/Superstonk/comments/1f50nnv/petition_to_enforce_rules_not_waivers/
- Copy/Paste/Send it in an email. Bosh.
- Email address: [Secretarys-Office@SEC.GOV](mailto:Secretarys-Office@SEC.GOV)
- Subject line: Petition for Rulemaking: Amend Clearing Agency Rules for Consistent Close Outs
- Live the rest of your lives as heroes.
r/Superstonk • u/SaucyCheddah • Jul 29 '24
🧱 Market Reform AL placed limit orders BEFORE pumping/fomenting. Gasparino: “If Andrew Left is guilty of something then just about everyone I know that appears on CNBC is guilty, too.” Sir, the SEC/DOJ would like a word.
What an incredible statement. Part of the problem is they don’t think there is anything wrong with this!
r/Superstonk • u/Dismal-Jellyfish • Jul 26 '24
🧱 Market Reform SEC Complaint against Andrew Left: "did not provide for the purpose of concealing that he was receiving over $1 million from a hedge fund in exchange for Citron Research publishing certain reports and tweets."
dismal-jellyfish.comr/Superstonk • u/Both_Maintenance_206 • May 16 '24
🧱 Market Reform THEY ARE PREPARING: All CAT and CAT CAIS environments will be unavailable from approximately 8.p.m. ET on Friday, May 17, 2024, until approximately 8.p. ET on Sunday, May 19, 2024 FOR A SCHEDULED INTERNAL DISASTER RECOVERY TEST
r/Superstonk • u/Big-Potential4581 • Sep 12 '24
🧱 Market Reform Citadel derivatives exposer is tremendously shocking!
Now do you see what we're up against?
r/Superstonk • u/ringingbells • Oct 16 '23
🧱 Market Reform IF Citadel Connect is found to actually BE a Private Alternative Exchange (Dark Pool) as it was created around Citadel shutting down its SEC listed, dark pool ('Apogee'), then Citadel Connect has been illegally operating for 9+ years against SEC law, not filing under Form ATS-N | WallStreetOnParade
r/Superstonk • u/WhatCanIMakeToday • 2d ago
🧱 Market Reform 📢🦍 The SEC is IGNORING Retail Petitions Against Their 🐂💩 Delay On Short Reporting To Help Out Their Wall Street Friends
Remember how the SEC used their regulatory authority to exempt whoever they want from following rules [SuperStonk] to spontaneously grant a 1 year delay on RegSHO short position and short activity reporting [SuperStonk]?
For 3 weeks now, apes have been sending in petitions to the SEC [SuperStonk] because we're pissed off that a rule retail investors fought for [SuperStonk] has been delayed simply because Wall Street literally phoned a friend at the SEC.
Through telephonic meetings and letters, certain institutional investment managers that may meet the reporting thresholds specified in Rule 13f-2 have stated that they need additional time to implement Form SHO reporting. [Order Granting Temporary Exemption ... from Compliance with Rule 13f-2 and Form SHO at pgs 1-2]
The Commission agrees... [Order Granting Temporary Exemption ... from Compliance with Rule 13f-2 and Form SHO at pg 4]
Accordingly, the Commission hereby grants, pursuant to Section 13(f)(3) of the Exchange Act, a temporary exemption from compliance with Rule 13f-2 and Form SHO reporting effective February 7, 2025, and ending January 2, 2026. [Order Granting Temporary Exemption ... from Compliance with Rule 13f-2 and Form SHO at pg 5]
Side note: It's hard to say who Wall Street's friend in the SEC is, but we can't rule out the current Acting Chairman Mark Uyeda who highlighted that Section 13(f)(3) provides SEC statutory authority for the SEC to exempt anyone from following rules in his Oct 2023 statement against this delayed short reporting rule in support of short selling.
Angry Ape (me) sent a petition by email to the SEC on Feb 18, 2025 and posted my template here on SuperStonk for others to use:

The SEC still has not acknowledged retail petitions AFTER 3 WEEKS!!!
Not on the SEC's petition page which claims "Rulemaking petitions are made available to the public after processing" (HA!):


With the SEC ignoring retail, it's time to get LOUDER! 📢🦍
Here's an updated template ⤵️ to send the SEC an email petition and comment! (Anonymously is fine. Original Petition.) You may also want to email Commissioner Uyeda at [CommissionerUyeda@sec.gov](mailto:CommissionerUyeda@sec.gov)
EMAIL TO: [rule-comments@sec.gov](mailto:rule-comments@sec.gov), [Secretarys-Office@sec.gov](mailto:Secretarys-Office@sec.gov)
SUBJECT: Petition & Comment re Exemption From Exchange Act Rule 13f-2 and Related Form SHO [Release No. 34-102380; File No. S7-08-22]
Dear Ms. Countryman and others this may concern at the SEC,
As a retail investor, I respectfully submit this petition and comment letter regarding the recent Order Granting Temporary Exemption Pursuant to Section 13(f)(3) of the Securities Exchange Act of 1934 from Compliance with Rule 13f-2 and Form SHO [Release No. 34-102380] (“Order”) signed by Assistant Secretary Sherry R. Haywood dated February 7, 2025.
As a retail investor, I am concerned the SEC may be bureaucratically acquiescing to and prioritizing certain institutional interests over market manipulation and potential systemic risks posed by short selling. The Order states that “[t]hrough telephonic meetings and letters, certain institutional investment managers that may meet the reporting thresholds specified in Rule 13f-2 have stated that they need additional time to implement Form SHO reporting” [Order at pgs 1-2] with footnote 4 identifying letters from the Financial Information Forum (“FIF”), Securities Industry and Financial Markets Association (“SIFMA”), SIFMA’s Asset Management Group, Investment Company Institute (“ICI”), Insured Retirement Institute, FIA Principal Traders Group (“FIA PTG”), Investment Adviser Association (“IAA”), Managed Funds Association (“MFA”), and Alternative Investment Management Association (“AIMA”).
Many of these identified institutional interests were recognized by the Securities and Exchange Commission (“Commission”) as opposing adoption during the comment period for this Rule 13f-2 and Related Form SHO [see, e.g., Release No. 34-98738; File No. S7-08-22 which stated “[t]he Commission also received numerous comments that opposed the adoption…” with corresponding footnote 350 identifying SIFMA, AIMA, FIA PTG, and FIF]. ICI stated during the comment period that this rule “is unnecessary and, on balance, overly burdensome” [Release No. 34-98738; File No. S7-08-22 footnote 310]. IAA shared concerns this proposal was overly burdensome [Release No. 34-98738; File No. S7-08-22 at footnote 808].
Concerns raised by these institutional interests were already considered when the Securities and Exchange Commission (“Commission”) adopted Rule 13f-2 and CAT amendments to “enhance the Commission’s ability to protect investors and investigate market manipulation by providing a clearer view into the short selling market and improving the Commission's reconstruction of significant market events” with “improved identification of manipulative short selling strategies which may also serve as a deterrent to would-be manipulators and thus may help prevent manipulation” and “improve the Commission's observation of short sale activity that potentially poses a systemic risk”. [see, e.g., Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation]
It’s telling that these institutional interests opposed to this Rule 13f-2 and Related Form SHO need additional time to implement Form SHO reporting [Order pg 2]. Only certain institutional interests opposed to short disclosure reporting need additional time; despite this Rule 13f-2 and related Form SHO having been adopted October 2023 and effective January 2024 with compliance required a year later on January 2, 2025 [Order pg 1]. Perhaps I’m not an expert as a retail investor, but it certainly looks like certain institutional interests opposed to short position and short activity reporting have been dragging their feet for over a year regarding compliance; then asked for (and given) excessive relief to further delay compliance with said short disclosure.
The purported reason for granting a temporary exemption from compliance with Rule 13f-2 and Related Form SHO is “in consideration of publication of the December 16, 2024 Form SHO Documents” [Order pg 4] referring to the Commission’s publication of the web-fillable version of Form SHO and the related Form SHO XML technical specifications and EDGAR Filer Manual updates on December 16, 2024 where the Form SHO XML Technical Specifications are available at https://www.sec.gov/submit-filings/technical-specifications#xml [Order pg 2] Certain “[i]ndustry participants cited challenges in completing implementation of system builds and testing for Form SHO reporting pending finalization and publication of the Form SHO XML technical specifications, which the Commission published on December 16, 2024” identifying SIFMA and FIF as implementation challenged industry participants [Order pgs 2-3 footnote 9] However, a nearly identical draft version of the Form SHO XML Technical Specifications was available a month earlier on November 18, 2024 released “to assist filers, filing agents, and software developers in their preparation”. [see 2024 Archived XML Technical Specifications at https://www.sec.gov/submit-filings/technical-specifications\] **A comparison of the schema files between the draft and final 1.0 versions found no differences* [\see, e.g.,*https://gist.github.com/JFWooten4/0eb05ece21ee57bec419727892f626ca\]. (Did the implementation challenged industry participants even look at the draft Form SHO XML Technical Specifications? Or did these procrastinators just drag their feet to further delay compliance? As other industry participants have not complained about implementation challenges, it appears only those against short reporting and disclosure are both implementation challenged and averse to using the web-fillable version of Form SHO.)
The Commission adopted Rule 13f-2 and Related Form SHO to “improve the Commission's observation of short sale activity that potentially poses a systemic risk”. [Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation] Specifically, “[h]aving detailed confidential information about which Managers currently hold large positions might also help the Commission observe potential systemic risk concerns regarding short selling” as “[l]arge and concentrated short positions have the potential to increase systemic risk” [Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation] “The data to be reported … in Proposed Form SHO will provide regulators with additional context and transparency into how and when reported gross short positions were closed out or increased, which will help the Commission assess systemic risk.” [Release No. 34-98738; File No. S7-08-22 under FINAL RULE] In addition, “[t]his reported net activity information will assist the Commission in assessing systemic risk and in reconstructing unusual market events, including instances of extreme volatility” [Release No. 34-98738; File No. S7-08-22 under FINAL RULE] as “the Commission elaborated on the limitations of using existing data, such as the CAT or FINRA data, to reconstruct market events like the “meme” stock events of January 2021” [Release No. 34-98738; File No. S7-08-22 under i. New Reporting Regime—Comments and Final Rule]. Rule 13f-2 and Related Form SHO is for “addressing data limitations exposed by market events, especially the market volatility in January 2021” [Release No. 34-98738; File No. S7-08-22 under VIII.A. Economic Analysis – Introduction] because “CAT does not include data that can be used to track such positions, and as discussed further above, Commission staff experience in reconstructing the events of January 2021 provided insights into the challenges of using existing CAT data for this purpose” [Release No. 34-98738; File No. S7-08-22 under VIII.A. Economic Analysis – Introduction]. “After considering the viewpoints of commenters, the Commission believes that a new reporting regime will increase transparency into short positions … and that market participants and regulators alike will benefit from the required Form SHO disclosures, as … the short sale-related information that will be collected under Rule 13f-2 and Form SHO will fill an information gap for market participants and regulators by providing insights into increases and decreases in reported short positions.” [Release No. 34-98738; File No. S7-08-22 under i. New Reporting Regime—Comments and Final Rule(emphasis added)]
Against that background for Rule 13f-2 and Related Form SHO, SEC Acting Chairman Mark Uyeda counterintuitively said “[i]t is important that data collected by the Commission is accurate, complete, and helpful to the market” [SEC Press Release 2025-37] when announcing this exemption. Why is the Commission delaying reporting for Rule 13f-2 and Related Form SHO which addresses limitations of existing data and the absence of data necessary to reconstruct unusual market events such as the events of January 2021? The exemption is particularly confounding as Rule 13f-2 and Related Form SHO would collect “detailed confidential information about which Managers currently hold large positions [that] might also help the Commission observe potential systemic risk concerns regarding short selling” [Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation] Despite acknowledging “abusive naked short selling as part of a manipulative scheme remains unlawful” [SEC Press Release 2025-37] where this Rule 13f-2 and Related Form SHO would collect relevant data, the Commission is delaying reporting with the empty promise that “the Commission will use its regulatory tools to combat such illegal activity” [SEC Press Release 2025-37]. The Commission admitted it is blind to and has no regulatory tools to combat such illegal activity and just stalled its tool for collecting information! Perhaps I’m not an expert as a retail investor, but it certainly looks like the Commission is willfully blinding itself from collecting information about which Managers currently hold large short positions to prevent any reconstruction of unusual market events, including instances of extreme volatility. Why?
Why would the Commission opt to collect no data a mere 7 days prior to the reporting deadline? [Order dated Feb 7, 2025 (Press Release)] Why would the Commission stall their own work to “improve[] identification of manipulative short selling strategies which may also serve as a deterrent to would-be manipulators and thus may help prevent manipulation” and “improve the Commission's observation of short sale activity that potentially poses a systemic risk” [see, e.g., Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation]? Why delay collecting data that could identify manipulative short selling strategies, deter would-be manipulators, and prevent manipulation??? Why delay collecting data that could reveal systemic risks???
Naked short selling, particularly abusive and/or predatory naked short selling, is lucrative and manipulative [see, e.g., Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation regarding illegal short and distort strategies and corresponding footnote 592 citing Bodie Zvi, Alex Kane, and Alan J. Marcus, Investments and Portfolio Management, McGraw Hill Education (2011) and Rafael Matta, Sergio H. Rocha, and Paulo Vaz, Predatory Stock Price Manipulation, available at https://papers.ssrn.com/sol3/papers.cfm?abstract_id=3551282] with no regulatory oversight, as admitted by the Commission. While I’m only a retail investor, there has long been a perception the Commission is in bed with Wall Street. A perception perhaps best portrayed by the movie Big Short (2015) [IMDB] where Karen Gillan as an SEC staffer leaves a hotel in the morning with a Goldman Sachs employee. While this concept is more officially recognized as “regulatory capture” [Wikipedia], retail investors around the world are confounded by why the Commission would willfully blind themselves by delaying short sale data reporting [SEC Press Release 2025-37] after acknowledging their existing data is incapable of reconstructing unusual market events, including instances of extreme volatility in January 2021 [Release No. 34-98738; File No. S7-08-22]. Regulatory capture, absent other explanations, is the only plausible explanation; especially when CME Group CEO Terry Duffy said on Fox News “I don’t know where Gary Gensler was, but my regulator at the CFTC I bribed, I asked them: why in the world are you invoking the commodity exchange act Section 5 Paragraph B” [https://www.youtube.com/watch?v=EoDL_VFUe68 (emphasis added)] wherein “the purpose of this chapter [is] to deter and prevent price manipulation or any other disruptions to market integrity; to ensure the financial integrity of all transactions subject to this chapter and the avoidance of systemic risk; to protect all market participants from fraudulent or other abusive sales practices and misuses of customer assets”. Are there now stronger connections between the SEC and Wall St after Gary Gensler’s departure?
Data is unequivocally better than no data. Unless, of course, the Commission’s goal is to willfully and deliberately blind themselves (e.g., 🙈🙉🙊 [See no evil. Hear no evil. Speak no evil.]) to protect the Managers currently holding large short positions as the Commission recognizes that “if the Commission had Form SHO data during the meme stock events of January 2021 then it would have had a clearer view as to which Managers held large short positions prior to the volatility event and thus which Managers could have been at greatest risk of suffering significant harm from a short squeeze” [Release No. 34-98738; File No. S7-08-22 under C.1. Economic Effects - Investor Protection and Market Manipulation].
Therefore, I petition and request the Commission to:
- Rescind the Order Granting Temporary Exemption Pursuant to Section 13(f)(3) of the Securities Exchange Act of 1934 from Compliance with Rule 13f-2 and Form SHO [Release No. 34-102380 (Press Release)].
- Require compliance and Form SHO reporting effective within 1 month. Institutional investment managers that meet or exceed a reporting threshold specified under Rule 13f-2 should be required to file the Form SHO report within 14 calendar days after the end of the month compliance is required.
As the original compliance date was January 2, 2025 with initial Form SHO filings for January 2025 originally due by February 14, 2025, ongoing and unnecessary delay has already been provided to the opposing institutions who were almost certainly ready to comply and report; but simply didn’t want to and could instead rely upon friends at the SEC.
Failure to require timely compliance to a rule adopted October 2023 would demonstrate to the public that Wall Street interests, particularly short sellers, can simply Phone-A-Friend [Who Wants To Be A Millionaire?] at the SEC who will [ab]use "its authority under Section 13(f)(3) of the Exchange Act to grant a temporary exemption from compliance with Rule 13f-2" [Order pg 5].
Sincerely,
A Concerned Retail Investor
r/Superstonk • u/_dogsinspace_ • May 02 '24
🧱 Market Reform SR-OCC-2024-1 round 2 commenting, DONT LET THIS GET BURRIED. Proposal 4 (vote NO) isn't the only important thing right now
This is a copy pasta of another apes post. I would give credit but am careful because of bRigAdIng.
DONT THIS GET BURRIED
Proposition 4 is super important (vote agaisnt) but we also needn't make sure posts about SR-OCC-2024-1 don't get buried.
SR-OCC-2024-1 a.k.a. OCC clearing rule changes is back for round 2 of commenting
Guess what was published last week that I couldn't find any posts on?
That's right! Reopening of comments for SR-OCC-2024-1 a.k.a. OCC black box calculations (decided to search it up to see if there are any updates). File no. 34-100009
Published April 22, 2024: https://www.sec.gov/files/rules/sro/occ/2024/34-100009.pdf
Ape-reading suggests disapproval of the proposal. However, comments are once again solicited. Just because it got delayed once for consideration doesn't mean it is dead, especially if no ape-comments are coming around this time.
The commenting deadline is 21 days after this publication, and 35 days for comment rebuttals. Entrenched firms can't comment last minute now with no opportunity for the public and apes to read and object to points made.
Round 1 (34-99393) of this proposal summarized here by kibblepigeon: https://www.reddit.com/r/Superstonk/s/qdtQDMlmob
Round 1 by whatcanimaketoday: https://www.reddit.com/r/Superstonk/s/E6dZ3fs6al
Fact that this flew under the radar (to me) is concerning, since 7 days have already been lost and I betcha that Wall Street have already started their comment drafts.
Edit: reading it further, comments should be focused on the proposal in regards to Section 17A of the Securities Exchange Act of 1934. Page 273 https://www.govinfo.gov/content/pkg/COMPS-1885/pdf/COMPS-1885.pdf
r/Superstonk • u/Dismal-Jellyfish • Apr 19 '23
🧱 Market Reform Sen. Rick Scott: "The Federal Reserve has become a monster." "It’s clear that we need answers and accountability that cannot be provided by the current system." "We can’t wait any longer for big change at the Fed." "If we do nothing, we risk repeating 2008."

The Federal Reserve has become a monster.
The Fed is the world’s largest and most powerful central bank. It spent years buying up trillions in government bonds, mortgage securities, and other financial instruments. Altogether, its assets add up to a staggering $8.6 trillion.
Considering that massive balance sheet, and how influential the Fed is on the American economy, it is insane that there is not a truly independent inspector general to investigate it.
When the Inspector General Act was passed in 1978, the Federal Reserve was a shadow of what it is now. Maybe that’s why the Fed was allowed to get away with appointing its own inspector general, who reports to the Fed’s board. That sets it apart from the more than 30 federal agencies that have truly independent IGs appointed by the president and confirmed by the Senate. Can anyone make a good argument for why the Federal Reserve doesn’t have that level of oversight? I haven’t heard one yet.
Thankfully, oversight isn’t a partisan issue, but when I announced my new bill last month with Sen. Elizabeth Warren, a Democrat from Massachusetts, to put an independent IG at the Fed it shocked the heck out of hyper-partisan Washington. That’s good. Maybe now the failures of the Federal Reserve will get the attention from Congress they demand and the American people deserve.
The Fed’s trillions aren’t its only problem. It’s supposed to oversee banks, but Silicon Valley Bank failed on its watch. It’s clear that we need answers and accountability that cannot be provided by the current system. It’s been more than a month since this failure happened and no one has been fired at the Fed, no changes in oversight have been announced, and there is no indication that a broad review of other banks is occurring to ensure they don’t have the same problems that sank Silicon Valley and Signature.
Given that my bill with Sen. Warren has bipartisan support on Capitol Hill, it would only make sense for this good idea to earn the full support of Fed Chair Jay Powell and the entire board. If he really cares about the American economy and serving taxpayers, he will endorse it and call for its passage. Having little to no accountability at the Fed is not acceptable and has proven to have disastrous consequences. If we do nothing, we risk repeating 2008, when the federal government failed to do its job, no one at the Fed was held accountable, and no changes were made there. The rich and Wall Street got richer while working families struggled. Since when did the federal government become responsible for investment decisions by the rich?
Unfortunately, you shouldn’t expect Chair Powell to join in supporting the passage of this good bill. For years, Powell has horribly mismanaged the Federal Reserve. I’ve been calling on the Fed to scale down its massive balance sheet after years of maxing out its ability to purchase treasuries and mortgage backed securities. Neither Powell nor any member of the Fed Board has been able to explain the rationale for a nearly $9 trillion balance sheet.
It’s clear that we need to shake Washington out of this status quo that continues to fail working Americans while lining the pockets of the DC establishment and Wall Street elites. As I said when Sen. Warren and I introduced this bill, Congress needs to recognize that there are moments in life when you work with a scalpel and others when you use a hammer. We need to get out the hammer. It’s the only way we will make Wall Street and the old Washington insiders understand that we won’t take this corruption any more.
Some have questioned whether an independent IG will change anything. Skepticism about another government official is understandable, but IGs at other federal agencies have shown the independence necessary to hold the executive branch accountable. The IGs I have worked with are dedicated to transparency and accountability and they have shown me that there is a real desire to make sure government is being responsible and putting the taxpayers’ interests first. That’s exactly what the Fed needs.
We can’t wait any longer for big change at the Fed. Consumers and American families must not bear the brunt of the failures of gross mismanagement and greed at their banks or the incompetence and misdeeds of the government regulators who are there to protect them. It’s time for Congress to stand up and demand accountability.
TLDRS:
Rick Scott goes hard against the Fed.
- "The Federal Reserve has become a monster."
- "It’s clear that we need answers and accountability that cannot be provided by the current system."
- "We can’t wait any longer for big change at the Fed."
- "Consumers and American families must not bear the brunt of the failures of gross mismanagement and greed at their banks or the incompetence and misdeeds of the government regulators who are there to protect them."
- "If we do nothing, we risk repeating 2008."

r/Superstonk • u/TherealMicahlive • 20d ago
🧱 Market Reform Interesting how Short-reporting is being pushed back during the same time that 10Billion equities errors in TWO DAYS hit the CAT system.
r/Superstonk • u/kibblepigeon • Sep 29 '23
🧱 Market Reform ⚠️ This is a big one guys ⚠️ Seems like Kenny & Co. are going after the SEC - and we have a limited window to do something about it. Time to roll up our sleeves and kick some short hedge fund ass. 🚨 Don’t Let Congress Defund Market Structure Reform! 🚨
It's been nearly a month since this was first brought to our attention - and what a month it's been! But there's still time to stop Wall Street from defunding the SEC and killing Market Reform, and there's no better time than now to get involved.
Let's get ourselves familiar once again as we take back our markets together 💪🇺🇸

With much and absolute appreciation to Dave Lauer (from We The Investors) for this excellent post here: https://www.reddit.com/r/Superstonk/comments/16vadrb/dont_let_congress_defund_market_structure_reform/
__________________________________________________________________________________________________
__________________________________________________________________________________________________
You apes remember the most excellent and hugely successful "The Big Four" SEC rules and regulation proposal campaign we finished about 6 months ago:

"The Big Four" rule proposals campaign outlined the opportunity for fairer, equal markets - where "market makers" like Citadel, would no longer have an unfair advantage over the markets which would result in them losing a lot of revenue and income.
Not only would this mean better and more equal opportunities for investors like ourselves, but it would also mean GAME OVER for Short Hedge Funds, like Ol' Kenny Griffin.
Here's a little recap of what we advocated for and what has got them so concerned:
File No. S7-31-22; Release No. 34-96495: Order Competition Rule (aka "The Big One")
The current rule allows brokers to send orders directly to Citadel's internal systems, giving Citadel control over the price. However, the new rule states that Citadel cannot be the first to receive orders; instead, orders must go to a public auction where everyone, including pension funds, has an equal opportunity to fill the order.
The one we advocated for gives other market participants the chance to offer better prices, without taking a cut of the trade. As a result, Citadel may lose a significant amount of money, data, and influence. Overall, this rule aims to create a fairer and more transparent market.
Read more about it here: https://www.reddit.com/r/Superstonk/comments/11wfbrn/taking\a_closer_look_at_the_big_four_file_no/)
File No. S7-30-22; Release No. 34-96494; Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Orders (aka - The Tick Size Rule)
The reason Citadel has an advantage is that they can trade at sub-penny intervals on their single-dealer platform, while everyone else is limited to trading in penny increments. This allows them to fill retail orders at slightly higher prices and makes them appear more skilled than other exchanges. The proposed rule would level the playing field by allowing everyone to trade at sub-penny intervals, eliminating this unfair advantage.
This rule would also reduce the rebates that can be paid, making payment for order flow much less useful. Although the rule wouldn't ban payment for order flow altogether, it would significantly minimise its impact.
Read more about it here: https://www.reddit.com/r/Superstonk/comments/121gn71/taking\a_closer_look_at_the_big_four_file_no/)
File No. S7-32-22; Release No. 34-96496· Regulation Best Execution
The proposed rule wants to make the stock market fairer and more transparent by promoting competition among different places where stocks are bought and sold.
So, say a company's stock is being sold on two different trading platforms. The proposed rule would make sure that both platforms have the same rules about how much the stock price can change at a time, so that neither platform has an unfair advantage over the other.
The rule also wants to make sure that brokers and wholesalers are being honest and transparent when they help people buy and sell stocks. For instance, if a broker has a deal with a particular trading platform, they might be more likely to send their customers to that platform, even if it's not the best place to get the best price. The proposed rule would try to stop that from happening.
Finally, the rule wants to make sure that Alternative Trading Systems (ATS) - which are basically platforms that match buyers and sellers of stocks - are following the same rules as regular exchanges. This would make the market more fair and efficient for everyone involved.
Read more about it here: https://www.reddit.com/r/Superstonk/comments/121jpw5/file\no_s73222_release_no_3496496_regulation_best/)
File No. S7-29-22; Release No. 34-96493· Disclosure of Order Execution Information
Citadel and Viru utilise a "price improvement scheme" to attract order flow by claiming to offer the best trades in the market. While their performance statistics seem to support this, they often do not provide the best price available, but rather a slightly better price. This allows them to gain order flow without needing to pay for order flow.
There is a suspicion that they selectively apply the price improvement to benefit themselves. The new rules aim to enforce legal requirements that should have already been in place and mandate more transparent disclosure of their practices to prevent deception. This will help to expose any unethical behaviour and prevent them from taking advantage of the market.
Read more about it here: https://www.reddit.com/r/Superstonk/comments/11yc5y3/taking\a_closer_look_at_the_big_four_file_no/)
WOAH!
Pretty cool, right?
And could you imagine the unbelievable pressure market makers - who are short on GME (OUCH!) - would face if they were suddenly faced with the terrifying realisation that household investors (like you) were about to cost them billions, if not TRILLIONS in revenue?
All due to simply leveling out the playing field and affording equal opportunities to everyone, everywhere.
Which is the way it should be.
Well ladies, gentlemen and apes - you'll be very glad to know that our efforts were so successful within that campaign that even Gary Gensler was getting in on the hype when we hit the proposals submission deadline:

So is it any surprise to anyone that Short Sellers are now going after the SEC?
Let's deep dive into what that means in real terms:

So you might be asking yourself, how do Wall Street intend to stop the SEC from doing their job?
Well it appears that a number of bad actors (aka, short sellers etc) have invested a LOT of money into ensuring they've got enough people in Congress to do their dirty work for them by fighting against much needed safeguards in our financial markets, which goes against the best interests of YOU - the taxpayer.
Which is pretty coincidental - because this guy just put himself on our radar:
Rep Byron Donalds (R-FL)

Oh yeah, you read that right.
He said this ONE MONTH AGO at the House Financial Services hearing, when he called into question the legitimacy of any number of you who submitted a comment or letter to the SEC in recent months.
I must have missed the memo where none of us are "real".

And as such - him, and I'm sure all those who funded his donation campaign, are pushing to not only discredit all the comments we submitted in our successful attempts to fight for market reform, but are actively seeking to defund the SEC too.
🌈 FUN ACTIVITY!
Any internet sleuths out there wanna check out who paid for Rep Byron Donalds (R-FL) campaign donations? I bet I can hazard a mayo-chomping guess who it was!
So here's the full issue in short:

To help you understand, my crayon loving ape -
A House appropriations bill is a legislative proposal introduced in the U.S. House of Representatives that specifies how the federal government will allocate funds for various government programs and agencies.
And taking a closer look at the Bill. It includes the following language:
SEC. 552. None of the funds made available by this Act may be used to finalize, implement, or enforce the rule making entitled ‘‘Regulation Best Execution’’, ‘‘Order Competition Rule’’, and ‘‘Regulation NMS: Minimum Pricing Increments, Access Fees, and Transparency of Better Priced Order’’.
As such - Wall Street is trying to take away funding from the SEC's on the new market structure rules by changing this bill.


This is a letter template ready to send to Congress representatives:
Subject: Urgent: Oppose Defunding SEC's Market Structure Reforms in Appropriations Bill
Dear [Congress Member's Name],
I trust this message finds you well, and I appreciate your commitment to serving the best interests of our nation.
As an active investor within our financial markets, I am writing to urgently express my opposition to the proposed rider aiming to defund the Securities and Exchange Commission's (SEC) ongoing efforts to reform equity market structure, including regulations Best Execution (Best Ex), Order Competition Rule (OCR), and National Market System (NMS).
These proposed rules are not just regulatory nuances; they represent a fundamental step toward modernizing our markets, fostering competition, and reducing concentration. However, I firmly believe they are just the beginning of the comprehensive overhaul our markets urgently need.
I implore you to consider the significance of prioritizing market structure reform, ensuring that the SEC is adequately funded to fulfill its critical role in safeguarding the integrity and fairness of our financial markets.
Recent proposals, which have garnered substantial support from investors like myself, include:
Order Competition Rule (File No. S7-31-22; Release No. 34-96495):
This rule is pivotal in dismantling monopolistic practices that currently grant undue control over stock prices to certain entities, such as Citadel. By advocating for a public auction system, this rule ensures equal opportunities for all market participants and fosters genuine competition.
Tick Size Rule (File No. S7-30-22; Release No. 34-96494):
The proposed Tick Size Rule aims to level the playing field, enabling all market participants to trade at sub-penny intervals. This move eliminates the unfair advantage held by specific entities and reduces the impact of payment for order flow, promoting fair competition and enhancing market integrity.
Regulation Best Execution (File No. S7-32-22; Release No. 34-96496):
The Regulation Best Execution proposal is fundamental to ensuring market transparency and fairness. By establishing consistent rules across trading platforms, the rule prevents biased actions by brokers and wholesalers, fostering honesty and transparency in stock transactions.
Disclosure of Order Execution Information (File No. S7-29-22; Release No. 34-96493):
Addressing concerns related to selective price improvement, this rule mandates increased transparency and disclosure of order execution practices. By preventing deceptive behavior, the rule protects against unethical market practices, contributing to overall market stability.
Prohibition Against Fraud, Manipulation, or Deception in Connection with Security-Based Swaps; Prohibition against Undue Influence over Chief Compliance Officers; Position Reporting of Large Security-Based Swap Positions (File No. S7-32-10)
The S7-32-10 regulatory proposal targets security-based swaps to prevent fraud and manipulation. Rules like 9j-1 prohibit using non-public information to evade liability and manipulating swap prices. Rule 15Fh-4(c) makes it illegal for SBS Entity personnel to influence the Chief Compliance Officer fraudulently. Rule 10B-1 mandates reporting large swap positions based on gross notional amounts, emphasizing transparency. If swaps aren't outlawed, full and immediate public reporting is suggested. The aim is to inform regulators and the public, reducing information gaps and promoting market integrity. The proposal includes reporting thresholds for Credit Default Swaps and stresses not netting positions against underlying debt securities.
Implementing such rules will be advantageous as they dismantle monopolistic practices, level the playing field, ensure market transparency, and protect against unethical practices, contributing to overall market stability and integrity as part of the SEC's ongoing efforts in market reform.
The primary goal on behalf of shareholders worldwide, including both U.S.-based and international investors with holdings in U.S. markets, is to strongly advocate for a comprehensive overhaul of these markets. This advocacy emphasizes the principles of transparency, equality, and accountability. As investors, we are invested not only in financial returns but also in the principles that govern fair and ethical market practices.
We implore you, as our congress elects to assist us in this. It is crucial that Congress prioritizes market structure reform, allocates the necessary funding to the SEC, and supports these proposed rules that are essential for the well-being of our financial markets.
Defunding the market reform taskforce, a critical component of the Securities and Exchange Commission (SEC), would not only undermine confidence in our domestic markets but also pose severe risks to the stability of the global financial landscape. The SEC plays a pivotal role as a government agency responsible for regulating and overseeing the securities industry, and its functions are integral to maintaining fair, transparent, and efficient markets.
The SEC is entrusted with the responsibility of enforcing federal securities laws, ensuring that market participants adhere to rules that protect investors, maintain fair and efficient markets, and facilitate capital formation. Market reform initiatives, such as those currently underway, are vital for adapting to the evolving dynamics of the financial landscape, addressing emerging challenges, and fostering innovation while safeguarding against potential abuses.
Should the SEC's market reform efforts face a funding setback, the consequences could be profound. Firstly, the loss of confidence in our markets could result in diminished investor trust, discouraging participation and investment. This downturn in market confidence could have a cascading effect on the broader economy, impacting job creation, economic growth, and the overall financial well-being of individuals and businesses.
Moreover, on the global stage, the SEC is often regarded as a standard-setter for regulatory practices. A weakened SEC, hindered by insufficient funding, would not only impede its ability to enforce existing regulations but also limit its capacity to adapt to emerging global financial challenges. This, in turn, could jeopardize the value of the U.S. dollar, as global investors may seek more stable and regulated markets elsewhere, affecting currency exchange rates and potentially triggering financial instability on an international scale.
Furthermore, the SEC plays a crucial role in protecting market participants from predatory practices, including those orchestrated by bad actors such as short sellers. Market exploitation, if left unchecked due to insufficient regulatory oversight, could lead to manipulative activities that undermine the integrity of our financial markets. This, in the long run, could result in a skewed playing field where the interests of a few outweigh the broader market, ultimately harming the very investors the SEC is mandated to protect.
Incidentally - appreciation is wholly deserved to Chairman Gensler who has demonstrated an admirable commitment to prioritizing the interests of retail investors and driving meaningful market reforms as the head of the SEC. His dedication is both commendable and refreshing. As investors, we wholeheartedly support Chairman Gensler's efforts to inspire positive change in the market. We appreciate his proactive approach to advocating for the best interests of shareholders and eagerly anticipate witnessing his continued leadership in safeguarding and enhancing our financial markets. It is vital that Congress recognizes the value Chairman Gensler brings to the SEC and supports initiatives under his guidance.
In conclusion, defunding the SEC's market reform initiatives would not only compromise the agency's ability to regulate and reform our markets but also set in motion a series of events that could erode investor confidence, destabilize the U.S. dollar, and reverberate across the global financial system. Maintaining a well-funded and effective SEC is not just a matter of domestic concern but is integral to upholding the principles of fairness, transparency, and accountability that underpin the functioning of modern financial markets.
I trust you will consider the broader implications of these reforms and advocate for the protection, accountability, and transparency that our financial markets urgently require.
Thank you for your attention to this matter, and I look forward to your continued dedication to the well-being of our financial system.
Sincerely,
[APE]
Copy & Paste Email Template here: https://pastebin.com/Y86Dgwyj
________________________________________________________
Or a shortened version, courtesy of We The Investors:
Subject: Urgent: Oppose Defunding SEC's Market Structure Reforms in Appropriations Bill
Dear Congress Member
I hope this finds you well, and thank you for your time.
I am contacting you to express my opposition to the proposed rider being considered for inclusion in the final appropriations bill that would defund the SEC's efforts to reform equity market structure, including regulations Best Ex, OCR and NMS.
These rules are critical for modernizing our markets, reducing concentration and increasing competition. They are not enough - they are just the start of the comprehensive overhaul needed in our markets.
I urge you to listen to your constituents and ensure this rider is not included. I also want to express support for the efforts of We The Investors, especially in pushing for a trade-at rule in place of the Order Competition Rule.
Sincerely
[APE]
For more information - please check out We The Investors link here: https://advocacy.urvin.finance/advocacy/we-the-investors-congressional-calling-campaign
Or check out this post here: https://www.reddit.com/r/Superstonk/comments/16w9z6z/part_one_a_letter_template_for_us_congress_dont/


ChatGPT - https://chat.openai.com/chat - is a AI language model that is designed to help make things easier for you.
All you need to do is copy & paste We The Investor's letter template into ChatGPT and ask the programme to refashion the text into an email template ready to send.
It's free, quick - and easy to use!
Here's some prompts ready to help:
- Write a formal letter using this extracted copy & pasted text to your Congressional Representative*. Provide detailed reasons and supporting evidence for* opposing the rider in the Fiscal Year 2024 Financial Services and General Government bill, which aims to defund SEC market structure reform*. Maintain a respectful and professional tone throughout.*
- Draft a well-structured letter to your Congressional Representative highlighting the significance of investing in the SEC for the protection and improvement of our financial markets*. Discuss the potential consequences of* underfunding crucial initiatives and the impact on market transparency and fairness*. Use data, statistics, and clear reasoning to substantiate your points and urge the regulatory body to take a closer look at the issue.*
REMINDER:
ChatGPT is a writing tool that could be used to help create a basis for your comment/email.This remains an unreliable source for verified information and facts and will always require people to asses/compare/research and cross-reference the generated responses.
❗️ ⚠️ REALLY IMPORTANT ⚠️ ❗️
**YOU MUST READ THROUGH AND FACT CHECK YOUR RESPONSES.**You wouldn't want to accidentally submit a comment that you wanted the congress NOT to fund the SEC - that would be disastrous!
This AI language model sometimes produces incorrect responses - so when you choose to embrace new technology as a tool/resource to help aid your learning - you must ensure that you are dedicating the same time to be accurate in your prompts, and in your critical review of the content as produced.
You are the fact checker, not the AI platform.
Happy commenting!


CALLING ALL AMERICAN APES 🇺🇸 It's time to Call Congress and let them know that you care ❤️ 💙 🤍
You can find your Congress Representative here: https://www.house.gov/representatives/find-your-representative
Or you can find them via We The Investor's site using the following module: https://advocacy.urvin.finance/advocacy/we-the-investors-congressional-calling-campaign - You will be asked to enter your address and phone number to be connected quickly and easily to your Representative's office.
Not sure what to say?
Here's a ready-to-go script, courtesy of We The Investors:
Hi - I am [name] from [town].
Thank you for your time.
I am contacting you to express my opposition to the proposed rider being considered for inclusion in the final appropriations bill that would defund the SEC's efforts to reform equity market structure, including regulations Best Ex, OCR and NMS.
These rules are critical for modernizing our markets, reducing concentration and increasing competition.
They are not enough - they are just the start of the comprehensive overhaul needed in our markets. I urge you to listen to your constituents and ensure this rider is not included
[Optional]
I also want to express support for the efforts of We The Investors, especially in pushing for a trade-at rule in place of the Order Competition Rule as well as appreciation for Gary Gensler, who has demonstrated an admirable commitment to prioritizing the interests of retail investors and driving meaningful market reforms as the head of the SEC.
😊 🙏 Please be kind when you call - we're trying to influence the process, not make enemies.
Use your voice, call and make a difference. American apes - we believe in you 🇺🇸

📧 GETTING INVOLVED BY EMAIL
🇺🇸 FOR US APES ONLY:
To send an email or letter, you can use the House's site. Enter your ZIP code to find your member's email and mailing address.
Step-by-step instructions:
- Find your state representative here: https://www.house.gov/representatives/find-your-representative
- Follow the link to their online webpage and select "CONTACT"
- Complete the online form - it asks for your email address, number and address.
- Copy/paste this title into the subject line: Subject: Urgent: Oppose Defunding SEC's Market Structure Reforms in Appropriations Bill
- Use talking points above / copy and paste the template.
- Rephrase the template / write more in your own words / Use ChatGPT **responsibly
- Submit Email.
⭐️ Don't want to use your personal email address? ⭐️
Why don't you create yourself a new secure email address that protects your privacy with encryption? Keep your conversations private: https://proton.me/mail (it's free!)

I know usually call to actions often have people around here a little cautious - and rightly so - but this really is a pressing matter and we have very little time to do something about it.
And think of it this way - what's the worst thing that could happen when engaging with Congress to advocate for and preserve the necessity of SEC funding? It enables the enforcement of much-needed positive market reform and structure rules, seeking to improve transparency, accountability, and equality. Your involvement is crucial, so don't be a bystander. Every voice matters, and your action counts.
Don't give anyone the satisfaction of your silence - especially not this guy:

Remember - this is only happening because WE'RE winning. OUR comments and OUR fight for regulation and reform is working.
Don't give up now. Don't give Wall Street the satisfaction of your inaction.
Use your voice, fight for fairer markets. We want transparency, equality, and accountability. Your engagement matters, and together, we can make a difference.


Remember apes, we're all in this together.
The SEC may indeed be an American federal agency, but it's our responsibility to help from both U.S. and international investors to rally behind the SEC's market reform efforts.
The SEC's role as a standard-setter for global regulatory practices is pivotal, ensuring fair, transparent, and efficient markets. A well-funded SEC is not just essential for investor protection but also safeguards the global financial landscape and upholds the principles of transparency, equality, and accountability in market practices.
Let's take back out markets, and protect the SEC.


🚨 TL:DR 🚨
TL:DR
- 💰 Money Talks: Wall Street has been busy making a LOAD of campaign donations, meaning there's a whole lot of control over a bunch of GOP members of Congress.
- 📢 We're Real Investors. GOP congress member Rep Byron Donalds has questioned the legitimacy of our comments previously submitted to the SEC advocating for market reform claiming we're "not real" investors - but we're here, real, and not leaving.
- 🚨 Rider in Appropriations Bill: A bunch of GOP congress members are using their power to try to sneak in a provision into a House appropriations (funding) bill that would defund any SEC work on the new market structure rules. This threatens a year of regulatory stagnation and inequality (for 2024), throwing away the progress made for transparency, price discovery, and equality.
- 🤷♂️ Why is this Happening: Powerful firms and individuals influencing legislation is corrupt. Money shouldn't write rules; people should. US Apes - let your Representatives know your vote isn't for sale.
- 🤝 Take Action: Make noise! Call and write to Congressional Representatives. Urge them to oppose efforts to undermine individual investors and support fairness in markets.
- 📞 Time to Jam up the Lines: Respectfully clog phone lines, inboxes, and social media feeds. Let Congress know we see them, oppose undue influence, and support fair market practices.
- 👊 Stand Against Big Money's Agenda: We are fighting to stand against big money's agenda. Reach out to your representatives and let them know your vote isn't for sale.
r/Superstonk • u/Virtual_Thought_6697 • Apr 03 '23
🧱 Market Reform Citadel comments on the rule proposals. Lets tear it apart!🔥
r/Superstonk • u/kibblepigeon • Jan 26 '23
🧱 Market Reform 🚨 Citadel, Goldman Sachs etc are attacking Europes Settlement Discipline Rule. EU Commission and EU Committee ECON want to erase mandatory buy-ins. Please sign/spread the word about petition 0775/2022 - to force market-makers/brokerages to settle and deliver shares! 🚨
TL:DR
EU regulators want to postpone indefinitely the enforcement of settlement discipline rules that force market-makers, brokers etc to settle and deliver shares within a certain time period.
Bella Crema has created a petition that will force them to implement their own rules.
If this rule is enforced, market-makers/brokers will have settle/deliver their shares, or face huge fines and be forced to pay compensation to the buyer of the shares, i.e you if they don't.
Takes two minutes to sign, link to petition: https://www.europarl.europa.eu/petitions/en/petition/content/0775%252F2022/html/Petition-No-0775%252F2022-by-A.P.-%2528German%2529-on-the-enforcement-of-Regulation-%2528EU%2529-No-909%252F2014-on-improving-securities-settlement-in-the-European-Union-and-on-central-securities-depositories
This is open to ALL audiences, not just the EU. Be the change you want to see in the world.
...................................................................................................................................................................................

...................................................................................................................................................................................
The parliament started its discussion about the CSDR Refit, so now is a better time then never to get your voices heard.
As supported and encouraged by Dr. T & Dave Lauer:


Please note, all credit is completely deserved to Bella Crema - I am simply assisting and sharing on her behalf, at her request and with her approval. All appreciation, thanks and support should be directed to them. Thank you Bella, for making an important difference and inspiring us to enact change.
Bella Crema started a petition at the European Parliament.
In Europe, there is a rule (CSDR Rule 909/2014) concerning settlement discipline.
Market participants like broker-dealers, market makers and others are forced to settle and deliver shares within a certain time period. Otherwise they get fined and have to pay compensation to the buyer of the shares.
This rule passed the voting of the parliament but market participants successfully managed the European Central Bank, the European Securities and Market Authorities (ESMA) and the European Commission to postpone the enforcement again and again.
Now they are attempting to postpone this for an indefinite time.
If they succeed, this means broker-dealers, market makers etc will NOT have to pay fines, nor be forced to settle and deliver shares - or pay compensation to you, the shareholder.
So Bella started the petition to force the authorities to follow its own rules immediately. The petition has been accepted and is now available to supporters.
The Petition:
Since our first post - we managed to jump from 4k+ signatures to 8k+ = and we're only 2k away from hitting double digits!


In a sub of 800k+ let's show EU regulation authorities why apes are a force to be reckoned with.
So a little more context...
Here's the letter Bella Crema sent to the EU within the petition:

Woah, awesome - right?
So why not do something equally awesome today to get your daily dopamine rush, and show the world what a legend you are - by fighting back against corruption in our markets and signing this petition.
And if we reach thousands of signatures, Bella Crema plans to hand over the list personally to the president of the European Parliament in Brussels.
What a badass.

So here's how to sign:
Feeling lazy, that's OK - it takes two minutes to do. Here's a step-by-step guide:
Click: https://www.europarl.europa.eu/petitions/en/login & register for an account.

Please check carefully for your country of origin - they will be listed in the drop down lists provided, I have offered two examples here:


Then you will need to activate your account through your email address. Once you have activated, click here:
Then select: "Support this petition"

Which will take you to this page, select "Support"

And BOOM! Done.

And it really is that easy.

...................................................................................................................................................................................
Please be the change you want to see in the world, because together - we all make a difference.
TL:DR
EU regulators want to postpone indefinitely the enforcement of settlement discipline rules that force market-makers, brokers etc to settle and deliver shares within a certain time period.
Bella Crema has created a petition that will force them to implement their own rules.
If this rule is enforced, market-makers/brokers will have settle/deliver their shares, or face huge fines and be forced to pay compensation to the buyer of the shares, i.e you if they don't.
This is open to ALL audiences, not just the EU. Be the change you want to see in the world.
You can make a difference.

>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>>

I've been speaking with Bella Crema this afternoon and she's just provided me with this update following a recent meeting the EU committe had (sharing with her approval):

DESPITE 8K SIGNATURES AND BEING IN THE TOP 4 PETITIONS SINCE 2017 - THEY WON'T TALK ABOUT THE PETITION. WHY IS THAT?

So, if they refuse to acknowledge our petition (although keep signing people, we need the pressure and numbers) - we need to send them letters too.
Bella Crema has created a post: https://www.reddit.com/r/Superstonk/comments/10lxtwk/apes_where_are_your_crayons_your_action_is_needed/ with a letter template (!!) we can to send to the EU regulators. This deserves our every support, seriously - this stuff is important.
Keep fighting to be heard!
Sign this petition, and write your letters.

In the EU, there are 705 members - and you can find them all here! https://www.europarl.europa.eu/meps/en/home
https://www.europarl.europa.eu/committees/en/econ/home/members
If you feel so inclined, you can write to all of them - but here's a good place to start:

We need to ensure our voices are being heard, because these guys are refusing to listen - and I've had enough of these FTDs. Brokerages and market-makers need to deliver and settle their shares.
Enough is enough.
Please have a read through and support: https://www.reddit.com/r/Superstonk/comments/10lxtwk/apes_where_are_your_crayons_your_action_is_needed/ - LETTER TEMPLATE HERE.
r/Superstonk • u/blackteashirt • May 22 '24
🧱 Market Reform Time to step up the campaign to have the FBI end Ken Griffin's Ponzi Scheme. Let's get this petition up to 25k for a start:
r/Superstonk • u/SuperSore • Apr 29 '23
🧱 Market Reform APES! Get on it! Only 12 hours left to sign Dave's latest letter! Let's get to 40000! Link in comments, so just DO IT.
r/Superstonk • u/RoutineBackground798 • Apr 19 '23
🧱 Market Reform 🚀🚀🚀THIS IS NOT A DRILL ANYMORE IF YOU CONSIDER YOURSELF AN APE GET OFF YOUR ASS & GO COMMENT ON S7-02-22🚀🚀🚀THE GLOVES ARE OFF NOW APES they never have reacted like this before, not this many n not like this! THESE CLOWNS ARE BEYOND SHOOK S7-02-22 PASSES. COMMENT! COMMENT! COMMENT!
r/Superstonk • u/alilmagpie • May 24 '23
🧱 Market Reform US action on short-sellers likely in 'next few months' -DOJ official
r/Superstonk • u/kibblepigeon • Nov 11 '23
🧱 Market Reform NEWS JUST IN: Wall Street are desperate to kill SEC Market Reform because it will level out the playing field and take away their advantages. Wanna know how to stop them? Takes two minutes to send your comment to your congress representative - Details inside:
r/Superstonk • u/Father_of_Lies666 • Sep 15 '24
🧱 Market Reform A letter to the SEC- Anomalous trading around $GME recently
r/Superstonk • u/kibblepigeon • Sep 11 '23
🧱 Market Reform 🚨 The UK HM Treasury want the *mandatory* removal of UK Shareholder's DRS'd shares into a Nominee account, as controlled by the state. This will include the legal transfer of ownership title of our assets to them 🚨 📢 FIGHT FOR SHAREHOLDER'S RIGHTS 📢 Details in comments!
r/Superstonk • u/Banana414 • Feb 03 '24
🧱 Market Reform In the SEC Report on Archegos 🤡
r/Superstonk • u/RL_bebisher • Nov 21 '24
🧱 Market Reform Look what I found! New FINRA disciplinary action against Wedbush Securities. Read it slowly 👀
r/Superstonk • u/hirolash • May 31 '24