Go / No-Go For Launch - The DTCC checklist keeping GME on the launchpad.

Possible DD 👨‍🔬

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 then 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

Opinon - Status: No-Go for Launch
DTCC would benefit most if new rules about payments in a member default situation are in effect prior to launch.

✅ = 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 src-1 / Now Expected week of April 26th-30th src-2 ❌
  src-1, src-2

• 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

• SR-DTC-2021-007: Update the DTC Corporate Actions Distributions Service Guide
  The “Stop bickering back and forth over the manual adjustments to your peer to peer trade records via the dumb APO method, and just use the GD computer validated Claim Connect system, please” Rule.
  Way to make a super vague title DTC… This is mostly about borrowed shares and updating who pays how much when circumstances - like rates - change. The old system (APO) needed both parties to just agree on the adjustments and one side could only submit an adjustment at a time, so it was rarely agreed upon in one pass and the bad guys could likely stall with many back and forths. To me this reads as a please use this better thing now, because APO will go away on July 9th 2021 so you’ll have to use Claim Connect by then anyways. Since the lender is likely incentivized to use the new system, it may get adopted in higher numbers sooner.
  Filed 2021-04-30, Effective Immediately, Mandatory 2021-07-09 ✅
  src, Explainer 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. This rule now appears to be clear to be acted on by the SEC.
  Possible insight on why this may have been strategically delayed, via /u/yosaso src-4
  NSCC-2021-801 Gave Advance Notice of this, and as of 2021-05-04 is cleared to be included with NSC-2021-002. src-2
  Filed 2021-03-05, Comment Period Extended to 05-31 / Expected action on or before 2021-06-21 src-3 ❌
  src, src-2, src-3, src-4

• 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

• NSCC-2021-005: Increase the NSCC’s Minimum Required Fund Deposit
  The “We’re gonna up your minimum deposit with us from an hysterically low $10K each, to an almost certainly still not enough $250k each” Rule.
  DTCC has submitted this to SEC, but SEC has not approved / published yet, so details may change. src-1
  Submitted 2021-04-26, Approved: Pending, Effective: Approval + 20days ❌
  src-1, Explainer post

• 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, Effective on or before 2021-05-21 ❌
  src

Non-regulation / Other Announcments

GOV-1085-21: DTCC / FICC White Paper Announcing WABR added as a Sponsored Member
WABR Cayman Limited is a firm specializing in helping Institutional Sales Traders in times of “thin markets”. u/stellarEVH explains:
“When a company needs to quickly pay off their debts as in the case of a margin call, it can be challenging for them to gather all the money from their various investments. There are firms in place that are specialized in liquidating their portfolio in a manner to minimize market impact while they pay off their debt.”
Announced 2021-04-23, Effective 2021-04-29
src, via this post & comments, linked from It’s Just a Bug, Bro Part 6 - Bug Spray Edition
Additional info on who WABR is 👀 Spidey senses are tingling
I love this community

MBS978-21: FICC Notice on MBSD Intraday Mark-to-Market Charge - Timing of Intraday Collection
We’ve been lenient for the past year cause shit was wack, but we’re going back on that regular hourly assesment for margins. ”Starting on May 3, 2021, the fixed time of 1:00PM will be eliminated and the MBSD Intraday Mark-to-Market Charge will return to an hourly assessment.” This combined with other things will tighten the screws.
/u/stellarEVH bringing that good good again: “For example, it’ll be much harder to short GameStop and/or trade in dark pools when you’re expected to cover your margin every hour. For the last year, they’ve only needed to prove they were covered at 1pm.”
Notice Date 2021-04-21, Effective 2021-05-03 ✅
src post, explainer comment

(please help me fill in other important rules via comments)

2 - Funding

Opinion - Status: Go for Launch
SR-DTC-2021-004 was likely the big one here, but SR-OCC-2021-004 would be very handy in the aftermath so it’s maybe 70/30 in my eyes.

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 (market-wide dive on 2021-04-22?) Citadel Sell-off?

• 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

• Big Banks do a Bond Sales, Citigroup: “Me Too!”

  • 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

Opinion - Status: No-Go for Launch
This will likely be the very last one, and we’ll only know what they will use as an excuse once it’s started. I think all the other pieces would need to be in place for them to feel most confident to light the fuse. This will be more oportunistic in nature, I think.

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

• Liquidity Stress Test - April 26th, 2021
  Note: the post title says 4 months early but over the last 8 years, its typically been a late April event. 2019/2020 in August appear to be anomolies.

• Government: POTUS joint address to Congress
  Green New Deal? Capital Gains Announcement similar to BS on 2021-04-22?

• Government: 2021-05-06 Congressional Hearing with SEC / Gensler, DTCC / Bodson, FINRA / Cook.

• Government: 2021-05-27 Congressional Hearing with Big Banks

• (other suggestions wanted)

4 - Fallguy, and the Lack of Prevention

Opinion - Status: Go for Launch
While they will likely have a fallguy decided upon prior to launch, I don’t see it as a necessity that would delay it, certainly not like the Rules of Engagement or Funding would. I also think that nothing would keep them from changing the story if something else influences the narrative in an acceptable way shortly after liftoff.

Blame!

After the market pain is significant enough that the public wants answers, why not 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)

  • Forbes article on January Gamma Squeeze

• Foreign Actors trying to destabilize the US Markets

• (other suggestions w/ sources wanted)

Control Public Image of the System via PR

• DTCC: “We’re doing a great job! Take our word for it!”

• DTCC: “We’re announcing our plan to keep working on a plan to kind of band-aid a problem that’s pretty bad and we’ve known about for awhile, and like we have definitely been talking about it and stuff, but now we’re like really gonna talk about it using words like “in-depth analysis” cause up to now we were mostly just talking about it like how you tell that one friend “yeah, we should totally hang out soon” and then you never do, but not now cause we’re serious now, and it’s definitely not because we’ve gotta talk to the US Congress this week or anything. Like, honestly.” AKA the DTCC’s T+1 Settlement Plan.

…Meanwhile, at the SEC

“Let’s at least look like we aren’t asleep at the wheel here, lads”

• Whistleblower Awards

• Closed door meetings

• 2021-05-13 Sunshine Act Meeting - Scheduled, postponed 4 times… so far!

• Speech by SEC Commissioner Peirce inlcuding the line that the SEC is “working on a report about the events related to meme stock trading earlier this year, and some regulatory initiatives may come out of that work.” and a few other statements about how the SEC shouldn’t be concerned with firms loosing money… aka Tough Titties Archegos, et al.
  src post

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:

Edit 1 on 2021-04-22:
Minor formatting.

Edit 2 on 2021-04-22:
Added NSCC-2021-801 note to the Finalized NSCC-2021-002 entry

Edit 3 on 2021-04-22:
Added link to DTC-2021-003, Emojis

Edit 4 on 2021-04-22:
Change NSCC-2021-002 to Pending - thanks /u/TensionCareful

Edit 5 on 2021-04-22:
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 on 2021-04-22:
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 on 2021-04-22:
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.

Edit 8 on 2021-04-24:
Updated expected date on SR-DTC-2021-005 refiling and sources, added DTCC planned stress test for 2021-04-26, notes on expected dates of other pending rules, MY OPINION on each category’s status for launch, other link for sources.

Edit 9 on 2021-04-26:
Added GOV1085-21 White Paper on WABR addied as new DTCC Member. Added DTCC non-reg announcements section.

Edit 10 on 2021-04-28:
Added dates to these Edits for clarity. Added DTCC filing of NSCC-2021-005. Added POTUS address to Congress as possible cover story for major market movements. Added Citigroup Bond offering, possible Citadel sell-off.

Edit 11 on 2021-05-02:
Added SR-DTC-2021-007. Updated date for postponed SEC closed door meeting. Added SEC Speech by Commissioner Pierce. Added upcoming congressional hearings - thanks /u/daveeyboy.

Edit 12 on 2021-05-03:
Updated effective date of SR-OCC-2021-004. Added MBS978-21 FICC Notice via /u/stellarEVH.

Edit 13 on 2021-05-05:
Updates NSCC-2021-801 as in the clear in Section 1. Added DTCC’s T+1 Settlement Plan announcement about kind of having a plan soon in Section 4.

Edit 14 on 2021-05-07:
NSCC-2021-002 officially delayed as far as June 21, 2021. Sunshine meeting for today postponed again.