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1. FTDs are at an all time high. Naked short selling is an epidemic. This is provably false.

2. Operational shorting as a part of market making and derivatives strategies is an enormous part of the market. This is also demonstrably false.

3. The DOJ has the resources, not the jurisdiction. Self regulation will always be underfunded. Trying to argue that short selling is an effective form of privatized self regulation is laughable.

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An increase in failures to deliver does not imply an increase in naked shorting.

They are highly correlated. Most other causes are static processes which would not increase or decrease.

The few firms (market makers) that are allowed to short naked pretty much always deliver.

By “cheque kiting”. Trading back and forth perpetually with colluding firms to perpetually “deliver”, eventually landing these phantom shares in offshore swap agreements where reporting has conveniently been perpetually delayed.

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