Author: /u/nothingbuttherainsir
OG Post link: https://old.reddit.com/r/Superstonk/comments/mvq6rs/go_nogo_for_launch_the_dtcc_checklist_keeping_gme/
TL;DR: DTCC & Wall St want key things in place before GME unwinds:
1 - Rules of Engagement
2 - Funding
3 - Cover Story for Timing
4 - Avoiding Perception of Responsibility
Official notice that this is not financial advice, etc etc. I have no idea if any of this is indeed why these things are happening, or if they are even what I think they are. I bought a handful of shares before DFV's Congressional hearing because something seemed fucky, and that was my first stock purchase EVER. If you make financial decisions off of this speculation, you probably do eat crayons like me. I am literally just some Ape on the internet mashing buttons and you're gonna have to explain to your wife's boyfriend why you took this as advice and the spent your whole allowance already this week.
So this last post from u/c-digs is about as close as anyone has come to my personal theory that there is a literal checklist somewhere that is getting marked off before this is allowed to unravel. The DTCC and Wall St (and probably the SEC) definitely do not want this spring to unwind before they are ready, and certainly not in a way in which they don't feel they are in control. These players are Big Corporate dicks with Big Corporate mindsets, and its my bet that they don't do anything without a plan that at least addresses all eventualities.
However, as it is now probably alarmingly clear to them this isn't just gonna go away on its own (cue Apes waving from the windows of the rocket sitting on the launchpad), the DTCC and pals are now scrambling to get the last things in place before somebody trips over the cord to the shredder at 3am and lands on the launch button.
I think the list goes something like this, but am intending this to be a crowdsourced document because there is no way I can keep this all straight on my own, and the GME Investor community has done so so much great DD already. There is definitely more to add in terms of DTCC / OCC / NSCC / SEC rules, and please comment with additional items & sources and I'll try to keep up with editing them into the list. Compiling it here can probably help determine just how close GME probably is to liftoff. It feels like we aren't that far from it now.
1 - Rules of Engagement
✅ = in effect now ❌ = pending review / revision
To Cover DTCC's own ass
-
SR-DTC-2021-003: Obligation to Reconcile Activity on a Regular Basis
The "You're gonna report your risk daily now, you little shits" Rule.
Filed 2021-03-09, Effective 2021-03-16 ✅
src -
SR-DTC-2021-004: Amend the Recovery & Wind-down Plan
The "We'll liquidate your asse(t)s if you default, then make your pals chip in, before we pay a dime ourselves" Rule.
Also stipulates what the DTCC is willing to cover when reconciling, as in only shares on the books, and why you (yes you Ape) should have a cash account and not a margin account.
Filed 2021-03-29, Effective Immediately ✅
src -
SR-DTC-2021-005 Removed by DTCC for Review
The "We're tagging the shares you lend out so you can't do it more than once" Rule.
Filed 2021-04-01, Removed for further Review / Status Unkown ❌
New on 2021-04-22
-
SR-DTC-2021-006: Remove the Security Holder Tracking Service
The "We're dropping the old way of tracking shares, cause it didn't work well, and DTC-2021-005 will do it better" Rule.
It was speculated in another post that the old system of tracking needed to be removed so there was no conflict in implementing DTC-2021-005 (I can't find that post here on reddit anymore, src needed!). It's likely that this could pave the way for 005 to be implemented. Filed 2021-04-22, Effective Immediately ✅ src <- also my post -
Exchange Act Rule 15c3-3 Compliance Letter: Staff Statement on Fully Paid Lending
The "We're making you keep full collateral on hand for your shit, you've got six months to get it together" letter.
Letter sent 2020-10-22, Effective 2021-04-22 ✅
src -
SR-NSCC-2021-002: Amend the Supplemental Liquidity Deposit Requirements Pending
The "We'll margin call you're ass if your new daily reports say you're overextended and make us feel scared" Rule.
Works in conjunction with DTC-2021-003. NSCC-2021-801 Gave Advance Notice of this.
Filed 2021-03-05, Proposed / under Review ❌
src -
SR-NSCC-2021-004: Amend the Recovery & Wind-down Plan
The "Just so we're clear about stocks specifically, we're really serious about us not paying for your fuckups unless we have to rule" Rule.
Works in conjunction with DTC-2021-004, but this is specific to securities and was filed first. src-1 This ALSO has language in it about clarifying the mass transfer of customer accounts from a failing member to a stable member. src-2
Filed 2021-03-05, Effective 2021-03-18 ✅
src-1, src-2 -
SR-OCC-2021-003: Increase Persistent Minimum Skin-In-The-Game / Waterfall Pending
The "You Market Makers are gonna give us more money now in case you fuck up with options later and owe someone more than you have" Rule.
This is the rule associated with the SR-OCC-2021-801 advanced notice, and SIG filed an opposition during the review period delaying the implementation.
Filed 2021-02-24, Effective 2021-05-31 (expected no later than 05-31, unless further opposition is filed) ❌
src
To cover the non-defaulting members, and the market in general as best as possible
- SR-OCC-2021-004: Revisions to OCC's Auction Participation Requirements Pending
The "Everyone can come to the feeding frenzy party when we liquidate one of you idiots" Rule.
Allows more firms that were traditionally excluded from an auction of this type to now join in, probably making the market wide bleeding end sooner, and retain more value overall.
Filed 2021-03-19, Pending ❌
src
(please help me fill in other important rules via comments)
2 - Funding
To pay out for shares of GME
- SHF Pulling money from crypt0
- SHF Pump and Dump on other stocks
- SHF Liquidate other Assets Under Management
- DTCC Wind Down and Recovery Strategy (SR-DTC-2021-004)
- (other suggestions w/ sources wanted)
Secure cash to buy up liquidated assets to prevent total market collapse
- Banks do a Bond Sales
- Need plausible reasons for making those sales such as earnings report, or LIBOR to SOFR switch, or insert wildcard like $50 Bil Football League, etc ...
- Banks Re-Structuring / Netting src
- New DTCC Rule SR-OCC-2021-004 allowing more players at the auction of the defaulting member's assets
3 - Cover for Timing of Launch
Ideally a plausible Corporate or Market Event that the stock price “should” respond to in order to initiate without the timing looking SUS AF and destabilizing broader market due to fear systemic problems.
- Corporate: AGM Voting Proxy Release
- Corporate: Dividend Issue
- Corporate: Major Partner Announcement
- Market: Global Supply Chain Issue
- (other suggestions wanted)
4 - Fallguy, and the Lack of Prevention
Blame!
After the market pain is significant enough that the public wants answers, lay all the blame on bad actors, and defer attention from the system to try to avoid additional exterior regulation.
- SHFs (now liquidated) as overly greedy and got what they deserved
- Retail (as Anarchists, or greedy and oportunistic)
- Foreign Actors trying to destabilize the US Markets
- (other suggestions w/ sources wanted)
Control Public Image of the System via PR
SEC
"Let's at least look like we aren't asleep at the wheel here, lads"
Any and all additions you think may belong on this list, feel free to put in the comments, and I'll try to update and give credit where possible. If I got any of these wrong, or you've found better links that explain the rules, let me know in the comments and I'll make those edits.
Big contributions from previous work on Recent Filings by u/Antioch_Orontes here:https://www.reddit.com/r/Superstonk/comments/msh5mt/a_brief_overview_of_recent_filings_from_the_dtc/
Edit 1: Minor formatting.
Edit 2: Added NSCC-2021-801 note to the Finalized NSCC-2021-002 entry
Edit 3: Added link to DTC-2021-003, Emojis
Edit 4: Change NSCC-2021-002 to Pending - thanks /u/TensionCareful
Edit 5: Added DTCC PR Campaign - thanks /u/vizsla_velcro, Added Global Supply Chain as possible launch cover - thanks /u/GrizzlyMagnum91, updated to "expected no later than" on OCC-2021-003 - thanks /u/slamweiss
Edit 6: Updated NSCC-2021-004 with more info from a post by /u/ecliptic10, that makes the mass transfer of customers from a failing broker to now be considered a Critical Service which are necessary functions of NSCC that can't NOT be done. Looks like more preparing for catastrophe.
Edit 7: Added SR-DTC-2021-006 effective immediately (April 22nd), which ends the old security holder tracking service, possibly making way for DTC-2021-005 which is the new tagging system for loaned shares.
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