V
VISA Inc.
stock NYSE

Do you like TOI.V as well? I’m in that pretty much fully (for me anyhow, 5%)

If it’s in a taxable account it certainly plays a part, to an extent. Google is used all the time and I own it in multiple account types but I was fortunate to buy at $144 in a taxable account back in April. I’m now up almost 100% but it’s short term. If I sell I’ll owe near 45% in taxes for federal and state.
That’s not a reason to never take a short term gain though. But for me to consider it I’d have to think Google will crash between now and April or I’d have to have another position I thought could nearly double as well. $30,000 gains less 45% taxes leaves me with $16,500. To get back to $30,000 I’d need an 82% gain on my $16,500.
I think the market is frothy for sure, but I’ve thought that for a full year. We got the “correction” in April, followed by a V shaped recovery (again). Timing is a fools game and Google is an amazing company. If I could sell now with no tax implications I might trim it and leave it in cash. But it doesn’t concern me enough to sell and take a 45% hit and I’m not chasing memes for gains at this stage, so I’ll hold.

Dump in morning, flat from 10-2, then massive V at close.

That is a fair point to make. I did not realize there is a phase 2 so that makes more sense. I have not done a bunch of research on this topic, still gathering what information I can to help make some good investment choices! So SCD.V is the only company that is dealing with scandium in Canada right now?

**MEMORANDUM FOR THE RECORD: DUE DILIGENCE REPORT ON POTENTIAL MARKET MANIPULATION THROUGH DEEP IN-THE-MONEY OPTIONS BUY-WRITES PERPETUATING FAILS-TO-DELIVER IN SHORT-SELLING ACTIVITIES**
**To:** **Federal Bureau of Investigation (FBI), Securities and Exchange Commission (SEC), Department of Justice (DOJ)**
**From:** [**Agent 31337**]; **I am not submitting these reports of evidence as I do not want to be placed under a gag order. Feel free to submit my findings. I will continue pursuing evidence and publicizing my findings via SuperStonk. THIS IS FOR THE PEOPLE, BY THE PEOPLE, POWER TO THE PLAYERS.**
**Date:** November 1, 2025
**Re:** Examination of Undisclosed Loopholes in Options Buy-Write Strategies Using Deep In-the-Money Calls to Evade Close-Out Requirements: Implications for Violations of Regulation SHO Rule 204 (17 C.F.R. § 242.204) and Securities Exchange Act § 10(b) (15 U.S.C. § 78j(b))
**Classification:** Unclassified; Public Submission for Investigative Review
**I. Executive Summary and Purpose**
This due diligence memorandum assembles verifiable evidence from SEC enforcement opinions, adopting releases, and regulatory guidance to illuminate an under-scrutinized settlement mechanism: the use of **deep in-the-money (ITM) options buy-writes** to create and indefinitely perpetuate fails-to-deliver (FTDs) without triggering mandatory close-outs under Regulation SHO Rule 204. In this strategy, broker-dealers pair stock purchases with the writing of deep ITM call options, which are immediately exercised and assigned, netting out in the Continuous Net Settlement (CNS) system to "reset" FTDs without actual share delivery to the National Securities Clearing Corporation (NSCC). This obscures the persistence of naked short positions, as assignments function equivalently to direct short sales but evade locate and delivery obligations for the underlying equity.
While designed for hedging, this practice exploits a structural gap in the interplay between the Options Clearing Corporation (OCC) exercise settlement and NSCC netting, allowing FTDs to age for months (e.g., 238 consecutive days in one case) without resolution. Unlike more visible tactics like total return swaps or ex-clearing, buy-write cycles are rarely flagged in public enforcement beyond isolated settlements, despite their role in amplifying short pressure in hard-to-borrow securities. Evidence indicates such strategies contributed to over 1,200 violations in a single broker's operations from 2008-2010, with FTD volumes exceeding $1 million in market value daily.
*No assertions of criminality are made; the facts compel investigation into systemic compliance. All data derives from free, public SEC documents as of November 1, 2025.*
**II. Factual Background: Mechanics of Deep ITM Options Buy-Writes**
A **buy-write** involves simultaneously purchasing stock and writing (selling) a call option on the same shares, typically at a strike price far below the current market (deep ITM, e.g., 57% below closing price). Upon execution, the deep ITM call is almost certain to be exercised immediately (e.g., 92% same-day assignment rate), assigning the obligation to deliver the shares to the call buyer. This creates a short stock position in the seller's account, economically equivalent to a direct short sale.
- **Settlement Process**: OCC processes option exercises by T+1, treating assignments as T+3 equity sales in NSCC's CNS system. The paired stock purchase and assignment net out in CNS's evening cycle, resulting in no net delivery from the broker's Depository Trust Company (DTC) account to NSCC. Subsequent buy-writes repeat the cycle, "resetting" the original FTD without closing it, as no shares transfer only the fail position carries forward.

- **Link to Synthetic Shorts and FTDs**: Initial synthetic longs (e.g., via selling puts and buying calls) hedge against declines, but buy-writes upon assignment convert to explicit shorts. Reg SHO Rule 204 requires NSCC participants to close FTDs by purchasing or borrowing like-kind securities by T+4 market open, with the transaction effecting delivery at CNS. Buy-writes evade this by netting internally, perpetuating "rolling" or "perpetual" fails without borrow costs or market impact.
- **Rationale and Scope**: Intended for income generation or hedging in volatile stocks, the strategy thrives in "hard-to-borrow" securities where put premiums exceed calls due to borrow fees. However, when used to respond to buy-in notices, it circumvents Rule 204's purpose: curbing abusive naked shorts by ensuring timely delivery.
**III. Extracted Data and Evidence of Potential Loopholes**
**A. SEC Enforcement Documentation on Buy-Write Abuse**
- Opinion of the Commission: optionsXpress, Inc. and Jonathan I. Feldman (Release No. 33-10125, August 18, 2016): Details 1,205 buy-writes from September 2008 to March 2010 in overpriced (OIP) securities (e.g., Sears Holdings Corp. (SHLD), The Talbots Inc. (TLB), China Sky One Medical, Inc. (CSKI)), with 67% executed after T+4 open (average 1.5 hours post-open, violating timing). FTDs persisted for 1,271 consecutive days across 44 periods, with optionsXpress responsible for 64% of all CNS fails among 273 brokers (ranking #1 in 26 periods). Commissions earned: $1,574,599. Violations: At least 1,200 instances of non-close-out, as buy-writes netted without delivery.

- Initial Decision: optionsXpress, Inc., Thomas E. Stern, and Jonathan I. Feldman (August 12, 2012): 97% of pre-August 2009 buy-writes after 10:00 a.m. ET; post-policy, 51% (average 58 minutes post-open). Correlation: Buy-write volumes matched FTD sizes (e.g., >0.9 for TLB assignments). Perpetual fail list (e.g., AIG, CMG, SHLD) issued 100% short notices, prompting cycles. Fails aged beyond T+4 (e.g., SHLD: 238 days, average $25M value; Citibank: 45 days, $9M average).
- Adopting Release for Amendments to Regulation SHO (Release No. 34-60388, July 31, 2009): Warns against "paired stock and option transactions" creating "appearance of bona fide purchase" but re-establishing fails without economic purpose, citing prior AMEX Arenstein cases (2007) fining buy-writes with deep ITM FLEX calls as evasions.
**B. Quantitative Indicators of Impact**
- FTD Volumes: In optionsXpress cases, SHLD fails: 238 days (April 8, 2009-March 18, 2010), averaging $25M; TLB: ~333,000 shares for weeks (February–March 2010); CSKI: ~20,000 shares (January-February 2010). Overall: 1,200+ violations, with next-highest broker fails dwarfed (e.g., SHLD: 2 days max). CNS summaries showed negative closing positions (ALLOC/RCYC insufficient), confirming no delivery.

- Assignment Rates: 94% of 395 trading days involved new buy-writes and assignments; 98% followed by next-day buy-write in same security; average streak: 12 days (max 50 in SHLD). Feldman: 390 buy-writes over 386/395 days (October 2008–March 2010).

- Premiums/Losses: SHLD example (September 16, 2009): $60.94/share upfront premium, but $60/share locked loss on expiration (October 16, 2009), netting $0.94/share profit minus fees. Strike: 57% below close.
**C. Specific Examples**
- **SHLD (September 16-October 16, 2009)**: 20,400 shares synthetic long ($70 strike); daily buy-writes (September 22-October 16, $0.01–$0.02/share cost); fails reset without delivery; expired with $60/share loss.

- **TLB (February 9-March 18, 2010)**: ~330,000 shares three-way trades; daily buy-writes (e.g., February 23: 335,900 shares/3,359 calls); 77% same-day full assignment; fails ~333,000 shares until close-out; 23 trading days of cycles.

- **CSKI (January 6-February 17, 2010)**: 20,400 shares/204 calls; T+3 fail January 11: 15,176 shares; daily buy-writes (e.g., January 12: 14,700 shares/147 calls); fails grew to ~20,000 shares.

- **UA (August 4-6, 2009)**: August 4 fail: 7,255 shares; buy-write: 7,200 shares/72 calls, assigned same day; fails continued (972 shares August 5; 5,572 August 6).

- Large Scale: December 31, 2009, SHLD: 516,600 shares/5,166 calls ($43M notional; 32% of daily U.S. volume).
**D. Regulatory Loopholes**
- Rule 204 Adopting Release (74 Fed. Reg. 38,270, July 31, 2009): Options assignments treated as equity sales under NSCC/OCC procedures, triggering SHO obligations; prohibits "sham reset transactions" like buy-writes maintaining fails. CBOE RG07-87/RG08-56 (2007–2008): Scrutinizes delta-neutral strategies evading close-outs, even for hedging.

- Hazan Capital Management Settlement (September 25, 2009): Similar buy-writes with deep ITM calls violated Rule 203(b)(3) (predecessor to Rule 204) as non-delivering resets.

- AMEX Circular Reg. 2007-35 (2007): Fined brokers for deep ITM FLEX buy-writes resetting fails without delivery.
**IV. Analysis: Potential for Concealing Illegal Activities**
Buy-writes exploit CNS netting and OCC exercise timing to mask naked shorts: Assignments mimic short sales but net against purchases, deferring delivery indefinitely and evading Rule 204's T+4 mandate. This understates FTDs in SEC data (only net reported), enabling price suppression in targeted stocks via persistent synthetic supply. Patterns mirror 2008 crisis warnings on option-equity pairings undermining market integrity, with risks to shareholder rights (e.g., voting dilution under UCC Article 8). Unlike direct shorts, options lack pre-borrow requirements, amplifying abuse in illiquid names.
**V. Recommendations for Investigation**
Audit broker OCC/NSCC logs for buy-write patterns in hard-to-borrow stocks; quantify unreported FTDs via CNS allocation data; review for Rule 204/10b-21 violations in recent enforcement gaps.
**End of Memorandum**
**[Agent 31337]**
**[FOR THE PEOPLE, BY THE PEOPLE, POWER TO THE PLAYERS]**
**Appendix: Sources**
- Opinion: https://www.sec.gov/files/litigation/opinions/2016/33-10125.pdf
- Initial Decision: https://www.sec.gov/files/alj/aljdec/2013/id490bpm.pdf
- Amendments to Reg SHO: https://www.sec.gov/files/rules/final/2009/34-60388.pdf
- Adopting Release: https://www.sec.gov/rules/final/2009/34-60388.pdf (74 FR 38270)
- Hazan Settlement: Referenced in above; full at https://www.sec.gov/litigation/admin/2009/33-9065.pdf

Great portfolio. As a nitpick, I'm not sure I love Novo as the largest holding. I like the setup overall, but pharma is a complicated industry with lots of moving pieces.
I might be a bit biased, but my portfolio has a lot of similarities to yours. Some other extremely high quality names you may want to look at: MELI, FTNT, BKNG, TOI.V, MA

**Proof:** [https://imgur.com/a/proof-AXhv0zF](https://imgur.com/a/proof-AXhv0zF)
**NGC slabs album:** [**https://imgur.com/a/ngc-slabs-kHrkL6v**](https://imgur.com/a/ngc-slabs-kHrkL6v)
**PCGS slabs album:** [**https://imgur.com/a/pcgs-slabs-E60XuNZ**](https://imgur.com/a/pcgs-slabs-E60XuNZ)
**Crowns album:** [**https://imgur.com/a/crowns-album-rLL3Z90**](https://imgur.com/a/crowns-album-rLL3Z90)
***Please ask for any close ups! SOME PRICES CHANGE WITH SPOT PRICE!!!***
**Payments:** **zelle** *(Strongly preferred)*, **PFFF**, and now **Venmo FF** and **crypto**
**Shipping:** risky **$1-2** depending on weight, USPS ground **$5** and sfrb **$10**. Other options and international shipping is available. Items sold today will be **shipped either Saturday or Monday** depending on the number of sales
**Trades:** I'm mainly **looking to sell my gold coins/silver bullion**, for my other coins, I'm looking for gold coins/bullion, silver bullion/junk silver (depends on asking price and items), walkers specific dates, Australian florins @ melt, and other world silver (especially older or large) for a good price.
***Spot price for coins are directly taken from other sites, I do not weigh each coin individually for wear and tear. Spot price fluctuations may render some old prices invalid.***
***Please ask for close ups***
***gold spot at time of posting: $4001.10***
***silver spot at time of posting: $48.60***
**GOLD:**
1910s $10 AU, bought from reliable dealer and tested with XRF - **~~$2050~~** **$2000**
# Silver Bullion:
2x 2025 collector's gold & gems poured 1/4 oz - **$14 ea**
2014 UK 2 pounds year of the horse - **$48.60 ($pot)**
Lot of 7 1800s morgans, AG/G no culls - **$37.50 ea (below melt!)**
India .917 assorted date 1 rupee (G-XF condition) - **$16.50 ea (below melt!)** \- around 10 still available
# Silver At Spot:
**!!BULK DEAL!! 97% of spot for order of $100 or more of world silver at spot**
|Coin|Price (numista melt)|
|:-|:-|
||
|"1780" Austria thaler restrike holed|$36.56|
|1858 Austria florin holed|$17.36|
|1892 Austria corona holed|$6.52|
|1961 Austria 5 schilling AU stain|$5.20|
|1962 Austria 5 schilling holed|$5.20|
|1958 Austria 10 schilling AU|$7.50|
|1958 Austria 10 schilling AU|$7.50|
|1971 Austria 10 schilling AU|$7.50|
|Canada dateless 10 cents George V|$2.90|
|1936 Canada 10 cents damaged|$2.90|
|1965 Canada 10 cents AU|$2.90|
|1911 Canada 25 cents worn|$8.43|
|2014 Canada 20 dollars .999|$12.44|
|1912 Can - Newfoundland 10 cents damage|$3.41|
|1917C Can - Newfoundland 25 cents VF|$8.43|
|1904 Can - Newfoundland 50 cents VF graffiti|$16.86|
|1900 Curacao 1/4 gulden worn|$3.58|
|1944 Curacao 1/4 gulden holed|$3.58|
|1944 Curacao 1/4 gulden stained|$3.58|
|1952 Dominican Republic 10 centavos stain|$3.52|
|1961 Dominican Republic 25 centavos VF|$8.79|
|1864 France 50 centimes holed|$3.26|
|1881 France 50 centimes VG|$3.26|
|1916 France 50 centimes VF|$3.26|
|1918 France 50 centimes AU|$3.26|
|1868 France franc very worn stained|$6.52|
|1917 France franc smashed|$6.52|
|1918 France franc VF |$6.52|
|1868 France 2 francs VG rim damage|$13.04|
|1898 France 2 francs stained|$13.04|
|1918 France 2 francs VF |$13.04|
|1961 France 5 francs UNC|$15.66|
|1905 Germany 1/2 mark holed|$3.91|
|1915 Germany 1/2 mark holed|$3.91|
|1875 Germany 1 mark damaged|$7.82|
|1887 Germany 1 mark holed|$7.82|
|1938 Germany 5 mark destroyed|$19.52|
|1971 Germany 10 mark Munich Olympics|$15.16|
|1990 Germany 10 mark 800 years teutonic order|$15.16|
|1917 Great Britain threepence VF cleaned|$2.05|
|1859 Great Britain sixpence plated holed|$4.09|
|1919 Great Britain sixpence VF|$4.09|
|1920 Great Britain sixpence G|$2.21|
|1921 Great Britain shilling VG|$4.42|
|1936 Great Britain shilling VF cleaned|$4.42|
|1929 Guatemala 5 centavos worn|$1.87|
|1943 Guatemala 25 centavos PVC|$9.37|
|1975 Israel 10 lirot UNC|$15.65|
|1863R Italy lira worn|$6.52|
|1927 Italy 10 lire rim damaged|$13.04|
|1959 Italy 500 lire XF/AU|$14.36|
|1952 Lebanon 50 piastres cleaned|$4.69|
|1937 Mexico 50 centavos holed|$9.37|
|1943 Mexico Peso lowball|$18.70|
|1948 Mexico 5 pesos holed polished|$42.20|
|1978 Mexico 100 pesos AU|$31.26|
|1918 Netherlands 10 cents worn|$1.40|
|1941 Netherlands 10 cents AU|$1.40|
|1918 Netherlands 25 cents holed|$3.58|
|1928 Netherlands 25 cents AU |$3.58|
|1965 Netherlands gulden holed|$7.31|
|1931 Netherlands 2 1/2 gulden crown XF|$28.13|
|1959 Netherlands 2 1/2 gulden VF |$16.91|
|1961 Netherlands 2 1/2 gulden AU cleaned|$16.91|
|1941 Netherlands East Indies 10 cents damaged|$1.40|
|1942 Netherlands East Indies 25 cents stained|$3.58|
|1944 Netherlands East Indies 25 cents stained|$3.58|
|1904 Panama 5 centesimos XF graffiti|$3.53|
|1904 Philippines 10 centavos XF holed|$3.79|
|1944d Philippines 20 centavos XF|$4.70|
|1945s Philippines 50 centavos VF|$11.76|
|1932 Portugal 2.5 escudos AU |$3.56|
|1944 Portugal 2.5 escudos VF|$3.56|
|1933 Portugal 5 escudos F|$7.11|
|1942 Portugal 5 escudos VF|$7.11|
|1940 South Africa 2 shillings cleaned|$14.14|
|1919 Sweden 10 ore XF rim damage|$0.90|
|1942 Sweden 10 ore VF|$0.90|
|1933 Sweden 25 ore holed|$2.27|
|1907 Sweden krona XF ex mount|$9.38|
|1946 Sweden krona XF|$4.38|
|1968 Sweden krona AU|$4.38|
|1957 Swiss 1/2 franc stained|$3.26|
|1962 Swiss 1/2 franc UNC|$3.26|
|1960 Swiss franc holed|$6.52|
|1961 Swiss franc holed|$6.52|
|1910 Swiss 2 francs polished|$13.04|
|1945 Swiss 2 francs ugly|$13.04|
|1932 Swiss 5 francs XF holed|$19.63|
|Venezuela dateless 25 centimos|$1.63|
|1960 Venezuela 25 centimos damage|$1.63|
|1929 Venezuela bolivar VG|$6.52|
|1935 Venezuela bolivar bent|$6.52|
|3x Germany third reich 5 reichsmarks, standard circulation 1934 + 2x 1935|$58.74|
|11x Netherlands & colonies 10 cents & 1/10 gulden|$15.51|
|4x Netherlands 1944 25 cents AU/BU|$14.32|
|3x Philippines 1944 10 centavos AU|$7.05|
|5.07ozt .500 silver, 95% of spot|$117.04|
# Lots:
50x .925 Canada silver 5 cents (lots of victoria, mostly culls but some are really nice) - **$2 ea**
# Singles:
1767 IK SC Austria thlaer PCGS VF details - **$175**
1894 Austria corona VG/F - **$8**
1899 Austria corona higher condition cleaned - **$8**
1912 Belgium Franc XF/AU nice - **$8**
1959 Bermuda Crown BU (rarer type, large .925 crown) - **$40**
1975 Bhutan 30 ngultrums UNC - **$20**
1895 Bolivia 50 centavos obv gunk - **$17**
1894 Canada 5 cents damaged not bad - **$8**
1901 Canada 10 cents holed AU - **$8**
1906 Canada 10 cents graffiti UNC - **$10**
1882H Canada 25 cents F damage (very rare date) - **$15**
1870 Canada 50 cents F plugged key date - **$20**
1871 Canada 50 cents G small graffiti key date - **$22**
1911 Canada 50 cents G much better date - **$16**
1865 Canada (Newfoundland) 20 cents AG - **$10**
1890 Canada (Newfoundland) 20 cents G - **$10**
1887 Chile 1/2 decimo XF holed - **$4**
1902 China (Kirin province) silver 10 cents PCGS F details - **$50**
1895-1907 China (Hupeh province) silver dollar PCGS VF details - **$300**
1897 Colombia 10 centavos CH AU - **$15**
19xx Cuba holed 10 centavos - **$4**
1915 Cuba 10 centavos solder - **$4**
1916 Cuba 10 centavos cleaned - **$4**
1915 Cuba 20 centavos damaged - **$8**
1915 Cuba 20 centavos rev cleaned - **$8**
1915 Cuba 40 centavos CH VF - **$22**
1919 Denmark 10 ore XF/AU - **$4**
1897 Dominican Republic 20 centavos AG - **$5**
1888 Birmingham Ecuador sucre VG (probably cleaned) mintage of 100k - **$45**
1888 Birmingham Ecuador sucre XF cleaned (mintage of 100k) - **$55**ea, 4 available
1888 Birmingham Ecuador sucre AU very light clean - **$65**
1897 Ethiopia 1/4 birr VG - **$12**
1947 Ethiopia 50 santeem (very rare) - **$12**
AN14 (1805)H (La Rochelle) France 1 franc Napoleon mintage of 7,149 G - **$50**
French (Napoleon portrait) franc sized coin (worn flat, maybe Italy?) - **~~$10~~** **$8**
1917 France 2 francs CH AU - **$14**
1831D France 5 francs old portrait VF- **$40**
1909A French Indo-China (Vietnam) piastre CH VF - **$50**
1943s Fiji shilling .900 AU hairlines - **$11**
1873 S Finland (Russian administration) 25 pennia CH XF - **$7**
1752JJJ Germany - Lubeck thaler NGC AU details cleaned, still has great lustre and details - **$225**
1866A Germany - Prussia thaler NGC AU details cleaned
1907A Germany 1/2 mark - **$4**
1876A Germany - Prussia 2 mark attractive VF - **$17**
1876B Germany - Prussia 2 mark F graffiti - **$16**
1876B Germany - Prussia 2 mark VG bent - **$16**
1912 Germany - Prussia 3 mark VF - **$26**
1912F Germany - Wuerttemberg 3 mark PCGS MS61 - **$90**
1938 Germany 2 mark AU - **$12**
1939 Germany 2 mark XF - **$12**
1900-B Great Britain Trade dollar PCGS AU details (harshly cleaned) - **$150**
1861 Great Britain 3 pence G - **$3**
1872 Great Britain 3 pence (very rare) XF hole - **$10**
1874 Great Britain 3 pence F - **$5**
1908 Great Britain 3 pence VG - **$3**
1838 Great Britain 4 pence holed F - **~~$8~~** **$7**
1888 Great Britain 6 pence VF holed - **~~$6~~** **$5**
1909 Great Britain 6 pence F cleaned - **$5**
1898 Great Britain shilling G - **$12**
1902 Great Britain shilling G - **$10**
1876 Greece 5 drachmai PCGS AU50 darker toning - **$185 (auction comps 200+)**
AN27 (1830) Haiti 100 centimes J.P Boyer AU/UNC, a bit of corrosion, very rare - **$60**
1907 Hungary 1 korona VF - **$9**
1939 BP Hungary pengo AU - **$10**
1939 BP Hungary pengo BU - **$15**
1936 BP Hungary 2 pengo (liszt) F - **$15**
1936 BP Hungary 2 pengo (liszt) AU - **$20**
1930 Ireland half crown F - **$18**
1863 Italy M BN lira VF - **$9**
1907 Italy lira - **$9**
1928 Italy 5 lire hairlines XF - **$10**
1903 Japan 1 yen UNC toned - **$110**
1904 Japan 1 yen AU toned - **$85**
1926 Japan 50 sen XF - **$11**
1937 Japan 50 sen VF - **$9 ea (2 available)**
1958 Japan 100 yen AU - **$6**
Japan 1960s silver 100 yen - **$6 ea (10+ available)**
1891 Mo AM Mexico 8 reales NGC UNC details cleaned - **$70**
1892 GA JS Mexico 8 reales NGC UNC details cleaned - **$75**
1890 CnM Mexico 10 centavos holed VF - **$10**
1943 Mexico 20 centavos AU stained - **$4**
1907 Mexico 50 centavos VF - **$17**
1921 Mexico 50 centavos AUNC slider, rare in UNC - **$50**
1938 New Guinea shilling BU UNC - **$12**
1947 Panama 1/4 balboa stains - **$10ea, 2 available**
1903 Philippines 10 centavos (large type) XF/AU - **$10**
1904s Philippines 10 centavos (large type) VF - **$6**
1944d Philippines 10 centavos BU - **$6**
1944s Philippines 50 centavos BU - **$17**
1944s Philippines 50 centavos PCGS MS65 - **$85**
1908 Russia 15 kopecks XF holed - **$4**
1916 Russia 20 kopecks AU cleaned - **$6**
1942 South Africa shilling - **$8**
1925 Soviet Union 15 kopecks XF/AU - **$5**
1905 S.M.V Spain peseta key date VG - **$17**
1850 Swiss 1/2 franc (very rare type and date) jewelry cull - **$12**
1963 Thailand silver 20 baht - **$26**
1950 Tibet 10 srang BU restrike proof - **$75**
1876 US silver quarter worn - **$10**
1953 Zimbabwe (Southern Rhodesia) crown UNC obv scratch - **$35**
# Ancients
330-280BC Greek - Lucania stater (nomus) NGC VF - **$225**
45BC Roman Pompey Jr denarius NGC AU 3/5 3/5 edge chip- **$350**
**end of post**

The most hated V shape recovery in history

V similar to 1st round

Yeah, true they weren’t in the first batch, but that’s pretty normal. The gov always funds in waves — phase 1 goes to shovel-ready projects (Rio, NMG), and phase 2 usually targets juniors in exploration and refining. Scandium is literally on Canada’s critical minerals list, and SCD.V is the only primary scandium play here. It’s early, not dead.

**MEMORANDUM FOR THE RECORD: DUE DILIGENCE REPORT ON POTENTIAL MARKET MANIPULATION THROUGH NSCC'S CONTINUOUS NET SETTLEMENT (CNS) SYSTEM FACILITATING PERSISTENT FAILS-TO-DELIVER IN SHORT-SELLING ACTIVITIES**
**PUBLIC SUBMISSION FOR:**
**Federal Bureau of Investigation (FBI)**
**Securities and Exchange Commission (SEC)**
**Department of Justice (DOJ)**
**From:** **[Agent 31337 - NOT A CAT for Public Submission]**
**Date:** November 1, 2025
**Re:** Examination of Undisclosed Loopholes in NSCC's Continuous Net Settlement System Enabling Chronic Fails-to-Deliver and Naked Short Selling: Implications for Violations of Regulation SHO (17 C.F.R. § 242.200 et seq.) and Securities Exchange Act § 10(b) (15 U.S.C. § 78j(b))
**Classification:** Unclassified; Public Submission for Investigative Review
**I. Executive Summary and Purpose**
This due diligence memorandum presents verifiable evidence from official regulatory documents, rule filings, and clearing corporation guidelines to identify an under-examined mechanism in U.S. securities settlement: the National Securities Clearing Corporation's (NSCC) **Continuous Net Settlement (CNS) system**. This system, while designed for efficiency, contains structural features that permit persistent Fails-to-Deliver (FTDs) by netting short obligations against participants' long positions, thereby masking the true scale of delivery failures from public reporting and regulatory enforcement. Such netting can facilitate naked short selling; selling securities without locating or borrowing them by allowing fails to accumulate indefinitely without triggering mandatory close-outs under SEC Regulation SHO Rule 204.
The CNS system's multilateral netting reduces daily settlement values by approximately 99%, but in doing so, it obscures FTDs that would otherwise require resolution. https://www.federalregister.gov/documents/2023/08/30/2023-18670/self-regulatory-organizations-national-securities-clearing-corporation-notice-of-filing-of-proposed?ref=dismal-jellyfish.com Only net FTDs exceeding a participant's account balance are reported to the Depository Trust Company (DTC) and publicly disclosed via SEC data, potentially understating chronic failures by 90% or more in heavily shorted securities. https://www.rareddit.com/r/Superstonk/comments/mwba7s/dtcc_the_final_boss__black_hole_liquidity/ This mechanism is not widely scrutinized in public discourse or enforcement actions, despite its role in enabling systemic opacity.
*No assertions of criminality are made; however, the facts warrant investigation into whether this contributes to manipulative practices, such as those observed in volatile equities where short interest exceeds available floats. Evidence is drawn exclusively from free, public sources including SEC rule releases, NSCC rulebooks, and federal notices, as of November 1, 2025.*
**II. Factual Background: Operation of the NSCC CNS System**
The NSCC, a subsidiary of the Depository Trust & Clearing Corporation (DTCC), operates as the central clearing entity for U.S. equities trades, processing over $2 quadrillion in annual settlements. https://www.dtcc.com/-/media/Files/Downloads/legal/service-guides/Settlement.pdf Its CNS system is an automated book-entry accounting platform that centralizes netting, allotting, and fail-control for trades from exchanges like the NYSE and Nasdaq. https://www.dtcc.com/clearing-and-settlement-services/equities-clearing-services/cns Under CNS, all buys and sells for each NSCC participant (e.g., broker-dealers, market makers) are netted multilaterally at the end of each day, resulting in a single net position per security per member. https://www.dtcc.com/~/media/files/downloads/legal/rules/nscc_rules.pdf https://www.sec.gov/files/rules/proposed/2022/34-94196.pdf
- **Netting Process**: Trades are aggregated such that only the final net settlement position requires delivery or receipt. For example, if a participant has 1 million long shares and incurs 400,000 short fails in a day, CNS nets the fails against the longs, eliminating visible FTDs unless the shorts exceed the account balance. https://www.rareddit.com/r/Superstonk/comments/mwba7s/dtcc_the_final_boss__black_hole_liquidity/ This occurs in two cycles: a "night cycle" for preliminary netting and a "day cycle" for final adjustments. https://www.researchgate.net/publication/228260887_Naked_Short_Sales_and_Fails_to_Deliver_An_Overview_of_Clearing_and_Settlement_Procedures_for_Stock_Trades_in_the_US

- **Fail Allocation**: If a broker fails to deliver by T+1 (post-2024 shortening), NSCC allocates the FTD randomly to another member with a net long position via its Stock Borrow Program or direct netting. However, CNS does not require immediate close-out if netted against surpluses, allowing fails to persist. https://www.sec.gov/files/rules/petitions/2025/petn4-848.pdf
- **Efficiency Metrics**: In 2022, CNS netting reduced settlement values by 99%, from trillions to billions daily. https://www.federalregister.gov/documents/2023/08/30/2023-18670/self-regulatory-organizations-national-securities-clearing-corporation-notice-of-filing-of-proposed?ref=dismal-jellyfish.com While this promotes liquidity, it creates a "black hole" for tracking individual fails, as only aggregate net FTDs are reported to DTC for public disclosure. https://www.sec.gov/comments/s7-07-23/s70723-20162302-331156.pdf
This structure contrasts with pre-CNS systems, where each trade settled individually, making FTDs immediately apparent. https://www.sec.gov/rules-regulations/2004/07/short-sales Historical reviews, such as the 1985 NASD Pollack Report, noted CNS's inability to prevent unlimited FTD accumulation. https://www.sec.gov/files/rules/petitions/2025/petn4-848.pdf
**III. Extracted Data and Evidence of Potential Loopholes**
**A. Regulatory Documentation on CNS Netting and FTD Masking**
- NSCC Rules (effective as of October 25, 2025): Define "Final Net Settlement Position" as the post-netting obligation, where fails are offset against longs before allocation. Rule 11 outlines CNS as the primary fail-control engine, but permits "protect" instructions on open fails for a $500 fee, delaying resolution. https://www.dtcc.com/~/media/files/downloads/legal/rules/nscc_rules.pdf
- SEC Proposed Rule Notice (File No. SR-NSCC-2025-004, published September 16, 2025): Proposes enhancements to CNS Fails Charge, acknowledging persistent fails by discontinuing charges on certain positions and allowing electronic "protects" to defer settlement. https://www.federalregister.gov/documents/2025/09/16/2025-17815/self-regulatory-organizations-national-securities-clearing-corporation-notice-of-filing-of-proposed This implies chronic FTDs are routine, with charges applied only to aged fails exceeding thresholds.
- Federal Register Notice (88 FR 59934, August 30, 2023; relevant to ongoing operations): Estimates CNS netting reduces CNS settlement values by 99%, but notes rare actual deliveries, allowing fails to net indefinitely if balanced. https://www.federalregister.gov/documents/2025/09/16/2025-17815/self-regulatory-organizations-national-securities-clearing-corporation-notice-of-filing-of-proposed

- SEC Short Sales Rule Release (Release No. 34-48709, 2004): Explains CNS nets all participant obligations, reporting only net FTDs, which can understate naked shorts by offsetting against unrelated longs. https://www.sec.gov/rules-regulations/2004/07/short-sales
- DTCC Settlement Service Guide (updated September 11, 2025): Describes CNS as netting to one position per member, centralizing fails but not mandating delivery if net zero. https://www.dtcc.com/-/media/Files/Downloads/legal/service-guides/Settlement.pdf
**B. Quantitative Indicators of Systemic Impact**
- FTD Data Reporting: SEC Fails-to-Deliver datasets (bi-monthly through October 2025) show aggregate net balances only, excluding intra-CNS netted fails. https://www.sec.gov/data-research/sec-markets-data/fails-deliver-data Between 2004-2009, FTDs represented 1.5%-5% of daily volume, but research indicates CNS hides up to 90% more by netting. https://www.researchgate.net/publication/228260887_Naked_Short_Sales_and_Fails_to_Deliver_An_Overview_of_Clearing_and_Settlement_Procedures_for_Stock_Trades_in_the_US https://www.rareddit.com/r/Superstonk/comments/mwba7s/dtcc_the_final_boss__black_hole_liquidity/
- Threshold Securities: Under Reg SHO, securities with FTDs >0.5% of float for five days enter the threshold list, but CNS netting delays this by offsetting fails. https://www.sec.gov/comments/s7-07-23/s70723-20162302-331156.pdf
- Historical Precedence: 2008 "Naked" Short Selling Antifraud Rule (73 FR 61666) notes CNS nets delivery obligations, but fails persist if not bought in, with NSCC guaranteeing only net positions. https://www.federalregister.gov/documents/2008/10/17/E8-24714/naked-short-selling-antifraud-rule
**C. Link to Short Selling Practices**
In naked shorting, sellers fail to locate borrows pre-trade (violating Rule 203), but CNS allows these to net against longs, avoiding close-outs. https://www.sec.gov/comments/s7-08-08/s70808-318.pdf
A 2009 academic overview details how CNS exemptions transfer fails without resolution, associating FTDs with naked shorts. https://www.researchgate.net/publication/228260887_Naked_Short_Sales_and_Fails_to_Deliver_An_Overview_of_Clearing_and_Settlement_Procedures_for_Stock_Trades_in_the_US Petition to amend Reg SHO (March 12, 2025) highlights CNS allocation of FTDs to random brokers, perpetuating chains without penalties. https://www.sec.gov/files/rules/petitions/2025/petn4-848.pdf
**IV. Analysis: Potential for Concealing Illegal Activities**
The CNS system's netting creates factual opacity: Fails can accumulate against participants' accounts without public visibility, enabling short sellers to maintain positions indefinitely. This may violate Reg SHO's close-out requirements (T+4 for non-market makers) by deferring delivery via netting. https://www.sec.gov/files/rules/proposed/2022/34-94196.pdf
In volatile stocks, this amplifies manipulation risks, as netted FTDs understate short pressure. https://www.sec.gov/files/rules/petitions/2025/petn4-848.pdf
Patterns resemble those in pre-2008 crises, where CNS hid delivery failures. https://www.sec.gov/comments/s7-21-16/s72116-6.pdf
**V. Recommendations for Investigation**
Request forensic review of NSCC CNS data for unreported FTDs; audit participant accounts for netting abuses; subpoena DTC/NSCC logs for threshold securities.
**End of Memorandum**
**[Agent 31337 - NOT A CAT]**
**Appendix: Sources**
- NSCC Rules: https://www.dtcc.com/~/media/files/downloads/legal/rules/nscc_rules.pdf
- SEC Shortening Settlement Cycle: https://www.sec.gov/files/rules/proposed/2022/34-94196.pdf
- Federal Register Notices: e.g., https://www.federalregister.gov/documents/2023/08/30/2023-18670/self-regulatory-organizations-national-securities-clearing-corporation-notice-of-filing-of-proposed ; https://www.federalregister.gov/documents/2008/10/17/E8-24714/naked-short-selling-antifraud-rule
- SEC Petition: https://www.sec.gov/files/rules/petitions/2025/petn4-848.pdf
- DTCC Settlement Guide: https://www.dtcc.com/globals/pdfs/2018/february/27/service-guide-settlement

- Research Paper: https://www.researchgate.net/publication/228260887_Naked_Short_Sales_and_Fails_to_Deliver_An_Overview_of_Clearing_and_Settlement_Procedures_for_Stock_Trades_in_the_US

What I read is that the government did not partner with SCD.V. They went with Nouveau Monde Graphite and Rio Tinto. What do you think this means for SCD.V? I am invested in them and hope it does in fact boost the price but why would it?

Source - [https://www.reuters.com/business/canada-accelerate-critical-mineral-projects-worth-46-billion-energy-minister-2025-10-31/](https://www.reuters.com/business/canada-accelerate-critical-mineral-projects-worth-46-billion-energy-minister-2025-10-31/)

**MEMORANDUM FOR THE RECORD: DUE DILIGENCE REPORT ON POTENTIAL SYSTEMIC MARKET MANIPULATION VIA TOTAL RETURN SWAPS AND CAYMAN-DOMICILED FEEDER FUNDS IN SHORT-SELLING ACTIVITIES TARGETING GAMESTOP CORP. ($GME)**
**PUBLIC SUBMISSION FOR:**
**Federal Bureau of Investigation (FBI)**
**Securities and Exchange Commission (SEC)**
**Department of Justice (DOJ)**
**From:** **[Agent 31337 – NOT A CAT for Public Submission]**
**Date:** November 1, 2025
**Re:** Urgent Examination of Undisclosed Synthetic Short Exposures Through Offshore Structures: Implications for Securities Fraud, Market Manipulation, and Tax Evasion Under 15 U.S.C. § 78j(b), 26 U.S.C. § 7201, and Related Statutes.
**Classification:** Unclassified; Public Submission for Investigative Review
**I. Executive Summary and Purpose**
This due diligence memorandum compiles verifiable evidence from public regulatory filings, investigative databases, market data, and social media intelligence to highlight a potential "smoking gun" in the ongoing scrutiny of short-selling practices targeting GameStop Corp. ($GME). Specifically, it focuses on the use of **total return swaps (TRS)** routed through **Cayman Islands-domiciled feeder funds** by major hedge funds and institutions (e.g., Citadel Advisors LLC, Susquehanna International Group, Millennium Management, and D.E. Shaw & Co.) to obscure massive synthetic short exposures. These mechanisms may enable evasion of SEC disclosure requirements under Rules 13d-3 and 10B-1, facilitation of naked shorting in violation of Regulation SHO (17 C.F.R. § 242.200 et seq.), and tax deferral schemes potentially amounting to evasion under IRC § 7201.
The purpose of this submission is to provide a comprehensive, fact-based dossier for federal review, drawing on real-time data as of November 1, 2025. No allegations of criminality are made herein; rather, the structures and data patterns warrant forensic investigation to ensure market integrity, protect retail investors, and enforce transparency. Evidence suggests these offshore TRS vehicles could mask short interests exceeding reported figures by 2-3x, contributing to volatility in $GME (e.g., 2021 squeeze events) and broader systemic risks akin to the Archegos Capital Management collapse in 2021, which involved $20B+ in undisclosed TRS losses. https://www.reuters.com/business/us-sec-chief-plans-scrutinize-short-sellers-rein-gamification-following-gamestop-2021-05-05/ Aggregate notional exposures in TRS for $GME alone may reach $1.56B across 43.6M synthetic shares, per public data extractions. https://x.com/odb123/status/1882116643511320750?s=46
**II. Factual Background: Mechanics of TRS and Cayman Feeder Funds**
A **total return swap (TRS)** is a derivative contract where one party (e.g., a hedge fund) receives the total economic performance (gains/losses, dividends) of a reference asset (e.g., $GME shares) from a counterparty (e.g., a bank), in exchange for periodic payments based on a fixed/variable rate. Unlike direct short sales, TRS allow synthetic exposure without borrowing shares, evading "locate" requirements under Reg SHO Rule 203(b) and enabling indefinite position recycling. https://corpgov.law.harvard.edu/wp-content/uploads/2008/06/sec-staff-advises-that-13d-disclosure-requirements-do-not-extend-to-total-return-equity-swaps.pdf
Hedge funds use TRS for leverage (up to 100x via repo collateral) and anonymity, as positions are not fully disclosed on Form 13F (derivatives exemptions) or short interest reports. https://www.skadden.com/insights/publications/2022/01/sec-proposes-new-disclosure-rule
**Cayman-domiciled feeder funds** operate in a master-feeder structure: U.S. investors "feed" into offshore Cayman entities (exempted under Companies Act), which pool capital into a master fund for tax-neutral trading. https://www.reddit.com/r/Superstonk/comments/1okgn8c/unmasking_cayman_islands_shell_networks_in/ Cayman hosts 80% of global hedge funds (12,000+ mutual funds per CIMA), with minimal public disclosure of beneficial owners. https://www.iosco.org/library/pubdocs/pdf/IOSCOPD653.pdf
These vehicles defer U.S. taxes on gains (IRC § 1291 PFIC rules) and obscure flows, routing TRS through layers to avoid real-time reporting under FATCA or FinCEN. https://www.haynesboone.com/-/media/project/haynesboone/haynesboone/pdfs/hb-hedgefund/hedge-fund-uk-section-two---the-fund-subsections-pgs-45-78.pdf?rev=8e6b6b7e2faf4bc1bca11ed4bf369a80&hash=5C1D34D12BE7C95FF3E0BB8CAEB78CCA
In short-selling, Cayman feeders hide notional shorts, amplifying risks: e.g., basis trades leveraging U.S. Treasuries ($1.4T-$3.1T in Cayman-held assets) for crypto/equity swaps.
Link to $GME: Public data shows TRS used to "hide" shorts post-2021 squeeze, with synthetic exposures recycling failures-to-deliver (FTDs) and suppressing prices via dark pools (52%+ off-exchange short volume). Citadel's $1T derivatives book (Q1 2025) includes undisclosed TRS hedges against naked shorts, per financial statements. https://x.com/gregiskitty/status/1911082582990532738?s=46
**III. Extracted Data and Evidence Supporting Potential Non-Compliance**
**A. Citadel Advisors LLC Exposures (CIK: 1423053)**
- Latest Form 13F-HR (Q3 2025, filed August 14, 2025): Discloses 4,945,930 $GME shares ($120.6M value), but excludes TRS/derivatives. Total AUM: $60B+, with $50B+ in short-equity positions via swaps. https://fintel.io/so/us/gme/citadel-advisors-llc Form PF (extended compliance to October 1, 2025) reports $10B+ in "credit default swaps and equity TRS," without $GME-specific breakdowns. https://www.sec.gov/rules-regulations/2025/09/s7-22-22
- Cayman Entities: Citadel Equity Fund Ltd. (CIMA #16805, est. 2017) – $10B+ AUM for equity shorts, including TRS; Citadel Value and Opportunistic Investments Partnership (est. 2024) – routes opportunistic shorts via layers. https://www.reddit.com/r/Superstonk/comments/1okgn8c/unmasking_cayman_islands_shell_networks_in/ Paradise Papers link to Appleby trusts for asset protection.
- TRS Data: $944B notional derivatives value, but only $6.5B assets/$4.7B liabilities reported; $221M equity TRS notional with $4M exposure – suggests counterparty (e.g., Bank of America) holds risk. https://x.com/trvsrdrgz2/status/1958003390279217339?s=46
$GME-specific: UPI QZ9KZ7GM9RJG (29.5M shares, $1.29B notional); QZVH174KGGX8 (14M shares, $267M). https://x.com/odb123/status/1882116643511320750?s=46 Total synthetic: 43.6M shares ($1.56B). https://x.com/odb123/status/1944577706911293715?s=46
- Revenue Context: Q1 2025 net trading revenue $3.4B (45% YoY increase); Q2 slump 8.4%. https://www.bloomberg.com/news/articles/2025-05-27/citadel-securities-mints-3-4-billion-in-record-first-quarter https://www.bloomberg.com/news/articles/2025-08-29/citadel-securities-second-quarter-trading-revenue-slumps-8-4
**B. Comparable Institutions**
- **Susquehanna (SIG, CIK: 1061768)**: Cayman feeders for $20B AUM shorts; $1B+ avoided gains offshore via basket options. IRS data flags deferral. https://www.reddit.com/r/Superstonk/comments/1okgn8c/unmasking_cayman_islands_shell_networks_in/
- **Millennium (CIK: 1362124)**: 50+ Cayman funds (e.g., #14567); $50B shorts via TRS in Form PF. https://www.reddit.com/r/Superstonk/comments/1okgn8c/unmasking_cayman_islands_shell_networks_in/
- **D.E. Shaw (CIK: 1104206)**: Oasis Cayman Fund (#11234); $40B arbitrage shorts. https://www.reddit.com/r/Superstonk/comments/1okgn8c/unmasking_cayman_islands_shell_networks_in/
- Sector-Wide: $435B asset increase in Cayman funds (2023 data); 80% U.S./Cayman domicile. https://www.cima.ky/upimages/publicationdoc/InvestmentsStatisti_1514498817.pdf https://www.iosco.org/library/pubdocs/pdf/IOSCOPD653.pdf
TRS tax issues flagged in 1999 Treasury report. https://home.treasury.gov/system/files/236/hedgfund.pdf
**C. $GME-Specific Indicators (2025 Data)**
- Short Interest: Official 16-20%; hidden synthetics 2-3x via TRS (e.g., XRT ETF 400% SI). FTDs missing in data for $GME, XRT, IWB. https://x.com/gregiskitty/status/1911082582990532738?s=46
- Warrants (CUSIP: 36467W117): Cash-settled TRS on warrants; potential unwind trigger. https://x.com/itsalwaysrains/status/1974844130208690607?s=46
- Social Intelligence: X posts reveal $12B+ notional TRS for $GME; counterparty risks, volatility catalysts. https://x.com/odb123/status/1882116643511320750?s=46 https://x.com/odb123/status/1944577706911293715?s=46
**D. Regulatory Loopholes**
- SEC Rules: TRS not deemed "beneficial ownership" under Rule 13d-3(a) absent control; cash-settled swaps undisclosed pre-2023 amendments. https://corpgov.law.harvard.edu/wp-content/uploads/2008/06/sec-staff-advises-that-13d-disclosure-requirements-do-not-extend-to-total-return-equity-swaps.pdf https://www.blankrome.com/publications/us-district-court-rules-against-hedge-fund-csx-corp-v-childrens-investment-fund-et-al https://www.proskauer.com/alert/second-circuit-sidesteps-whether-equity-swaps-confer-beneficial-ownership
Proposed Rule 10B-1 requires large SBS disclosure, but exemptions persist. https://www.proskauer.com/alert/in-a-trinity-of-releases-the-sec-proposes-to-make-hedging-transactions-more-transparent https://www.skadden.com/insights/publications/2022/01/sec-proposes-new-disclosure-rule
Form PF extensions (to Oct. 2025) delay reporting. https://www.acaglobal.com/industry-insights/sec-action-extends-form-pf-filing-deadline-further-extensions-may-follow/ https://www.mayerbrown.com/en/insights/publications/2025/06/sec-and-cftc-extend-compliance-date-for-form-pf-amendments-and-sec-withdraws-certain-proposed-rules https://www.federalregister.gov/documents/2025/09/19/2025-18228/form-pf-reporting-requirements-for-all-filers-and-large-hedge-fund-advisers-further-extension-of
- Tax Implications: Offshore TRS defer $16.6B+ annual U.S. revenue; high-cost borrowers (hedge funds) as receivers. https://home.treasury.gov/system/files/236/hedgfund.pdf
**IV. Analysis: Potential for Hiding Illegal Activities**
These structures create opacity: Cayman exemptions limit beneficial owner registers; TRS evade T+2 close-outs, enabling naked shorts and FTD resets. For $GME, this may understate short interest, inflating synthetic float (100M+ shares) and risking squeezes. https://x.com/gregiskitty/status/1911082582990532738?s=46 Patterns mirror Archegos (swaps hiding $20B losses) and LTCM (1998 crisis via TRS leverage). https://home.treasury.gov/system/files/236/hedgfund.pdf Tax deferral via feeders could evade reporting (e.g., $1B+ for SIG). **Warrant exercises may force unwinds, exposing fraud.** https://www.sechistorical.org/collection/papers/1990/1999_0401_LTCMReport-1.pdf
**V. Recommendations for Investigation**
Request audits of Cayman feeders via FATCA/IRS Form 3949-A; review Form PF/13F for TRS mismatches; subpoena CIMA registries; analyze $GME FTDs/dark pools.
**End of Memorandum**
**[Agent 31337 - NOT A CAT]**
**Appendix: Sources**
- SEC EDGAR (e.g., 13F-HR: sec.gov/edgar/browse/?CIK=1423053). https://fintel.io/so/us/gme/citadel-advisors-llc
- ICIJ Paradise Papers (offshoreleaks.icij.org). https://offshoreleaks.icij.org/nodes/80045719
- CIMA Registry (cima.ky). https://www.cima.ky/upimages/publicationdoc/InvestmentsStatisti_1514498817.pdf
- X Posts (e.g., IDs 1882116643511320750, 1944577706911293715). https://x.com/odb123/status/1882116643511320750?s=46 https://x.com/odb123/status/1944577706911293715?s=46
- Federal Register/SEC Releases (e.g., 89 FR 17984). https://www.federalregister.gov/documents/2025/09/19/2025-18228/form-pf-reporting-requirements-for-all-filers-and-large-hedge-fund-advisers-further-extension-of

Anyone have thoughts on Doubleview Gold $DBG.V and their claim on the worlds largest scandium deposit at their Hat deposit in northwest BC?

Well with the recent (friday) announcement by Carney and the state of the relationship CAN-US, I think Canada is gonna put some more love inside its home. Plus Carney directly mentionnee Scandium as one of the focus… 2 players are in Scandium, Rio Tinto gets it indirectly from one of their process and Scandium Canada (SCD.V) sits directly at Crater Lake on one of the world's most significant primary sources of scandium.
I think Scandium Canada is a good horse to bet on! Plus the stock is quite cheap

Stocks I have in each quarter
Jan / Apr / Jul / Oct → KO, TROW, MDLZ, KMB, PEP, DEO
Feb / May / Aug / Nov → VZ, COST, PG, MA, AXP, STZ
Mar / Jun / Sep / Dec → JNJ, CVX, XOM, LMT, V, UNH, HD
I have ETFs too with VOO, VT, VGT, and VUG.
Are those quarterly stocks good to have for long term and strong dividends to use as passive income on the side? I am open to your suggestions and advice too.

Keep waiting for a 30% drop after 150% gains, so you can say: I bought low.
Then you get a V shape recovery 😂

**Disclaimer:** First of all, nothing discussed below is an investment recommendation, simply an opinion. Some data could be wrong. **Do Your Own Research (DYOR).**
Today we are going to talk about raw materials, specifically **uranium and vanadium**, and one of the largest undeveloped deposits in the world.
# The Backstory: Why Did Sweden Ban Uranium?
This story starts back in 1979. In that year, the world was shocked by the **Three Mile Island** nuclear accident in the United States 🇺🇸.
One year later, a Referendum in Sweden 🗳️ established a clear mandate to **phase out nuclear power** in the country. This established a national anti-nuclear energy policy that lasted for decades, leading to the premature closure of several reactors.
In 2018, that policy culminated in the **total ban on uranium mining activity** 🚫.
This was set in the Swedish Minerals Act and Environmental Code, which explicitly banned uranium exploration and mining. Importantly, this law also prohibited the extraction of uranium *even if it was found as a byproduct* of mining for other metals (such as iron or rare earths).
# The Present: The Uranium Macro
Let's return to the present. The world is on the brink of unprecedented technological change (AI, EVs, Data Centers) that will lead to an exponential increase in energy consumption. At the same time, awareness of climate change is forcing governments to seek cheap, clean, and *reliable* sources outside of fossil fuels.
The world seems to have (re)found a possible long-term solution: **nuclear energy** ☢️.
Worldwide, there are plans to build **more than 100 nuclear reactors** in the coming decades. As is well known, the fuel that powers them is uranium. It is therefore reasonable to assume that demand for uranium will grow.
The tension begins with *who* controls it.
# The Geopolitics of Uranium
* **🇰🇿 43%** of this resource worldwide is controlled by **Kazakhstan** (under Russian influence 🇷🇺).
* **🇳🇦 11%** by **Namibia** (under Chinese influence 🇨🇳).
* **🇨🇦🇦🇺 \~25%** is "safe" in Western hands (Canada & Australia).
* **🇳🇪 \~5%** is barely controlled by France via Niger (now highly unstable).
**Conclusion: This is not nearly enough for the West.**
And what about Europe? 🇪🇺 Europe has been legislating without control for decades, turning its back on real problems. But... there is hope, at least in the north.
# 🇸🇪 Sweden's 180-Degree Turn
In the last year, the Swedish government 🇸🇪 has announced aggressive plans to **massively expand nuclear power** . Their goal is to build at least **10 new reactors** (including small modular reactors or SMRs) by 2045 and double the country's electricity production.
# 🗓️ THE CATALYST: NOVEMBER 5TH!
And pay attention!! On **November 5th** (in 4 days), the Swedish parliament will vote on a proposal to amend the 2018 law and **allow uranium mining once again**.
The amendment to the law would come into effect on **January 1, 2026** (you had 2016, this is a key correction!), and would open up a path that has been closed for decades.
Let's assume that the bill is passed. Otherwise, the story ends here.
# 💎 What is District Metals ($DMX)?
District Metals Corp. (DMX) is a junior mining exploration company 🇨🇦, whose business model focuses on the acquisition and development of mineral projects in Sweden 🇸🇪. It has several projects, although the ones that interest us are Gruvberget and especially **Viken**.
**Viken is considered the largest undeveloped uranium deposit in the world** (or the second largest, after Olympic Dam in Australia).
# The Good: MASSIVE Tonnage
The deposit, hosted in Alum Shale, has a massive tonnage.
* **4.333 Billion tonnes** in the Inferred Category.
* **456 Million tonnes** in the Indicated Category.
|Category|Tonnage (Millions)|U3O8 (ppm)|V2O5 (ppm)|Mo (ppm)|Ni (ppm)|Cu (ppm)|Zn (ppm)|
|:-|:-|:-|:-|:-|:-|:-|:-|
|**Indicated**|456|175|2,836|257|330|113|411|
|**Inferred**|4,333|161|2,543|240|321|118|417|
# The Not-So-Good: The Grade
The grade (concentration) is low. This limits the viability of mining *only* uranium. The profitability of the project is based on the co-recovery of high-value by-products.
And here is the magic. Look at the total contained metal (in millions of pounds):
|Metal|Inferred Category (Mlbs)|
|:-|:-|
|U3O8 (Uranium)|1,538|
|**V2O5 (Vanadium)**|**24,295**|
|Mo (Molybdenum)|2,293|
|Ni (Nickel)|3,067|
|Cu (Cobre)|1,127|
|Zn (Zinc)|3,984|
The project is essentially a **world-class Vanadium deposit** with a massive Uranium credit.
# Project Strengths
1. **Massive Resource Scale & Deposit Geometry :** The alum shale deposit is shallow and relatively flat-lying. This makes it ideal for conventional "shovel and truck" open-pit mining.
2. **Exceptionally Low Strip Ratio :** This favorable geometry translates into an extremely low strip ratio, historically confirmed at **0.5:1** (half a ton of waste rock for every ton of ore).
3. **Low Mining Costs :** The low strip ratio generates very competitive mining costs, estimated at **\~$3.00 per ton of ore**.
4. **Cash Flow Drivers :** Profitability is based on by-products. Key metals include **Vanadium** as the main driver, Molybdenum, Nickel, and Copper: all are critical metals essential for the energy transition and defense.
5. **Economic Robustness :** Polymetallic diversification acts as a strategic hedge against the price volatility of a single commodity.
# Main Risks
# 1. Metallurgical and Technical Risk
This is the main technical obstacle.
* **Complex Rock:** Alum shale is a complex rock. The metals are chemically bound, requiring complex hydrometallurgical processing (bioleaching) to release them.
* **Bioleaching Risk :** It's a slow process (leaching cycles can last hundreds of days) and faces technical challenges.
* **Reagent Consumption (OPEX) :** Alum shale is a carbonaceous rock. If it consumes too much acid in the process, the Operating Costs (OPEX) could skyrocket, making the project unviable.
(All these risks are typical of many mining activities and are technically surmountable.)
# 2. The Real Risks (For Me):
* **Environmental Cost Risk :** Swedish legislation is extremely strict, much more so than other jurisdictions, which could reduce profitability.
* **Risk of Municipal Veto (Kommunalt Veto) :** This is the most imminent legal risk, as Swedish municipalities have veto power. **HOWEVER**, recent information suggests the new law would change this classification for uranium mines, meaning this veto might not be applicable. Still, there is strong local opposition that the company must overcome.
# Two Aces Up the Sleeve
1. **SGU (Geological Survey of Sweden) 🇸🇪:** The SGU has the authority to designate areas for “valuable substances.” This gives the project enormous credibility and would support the granting of licenses.
2. **EU Strategic Project (CRMA) 🇪🇺:** The main route for Viken is designation under the **EU Critical Raw Materials Act (CRMA)**. This is only granted to projects that address Europe's security of supply. If granted, it would provide clear advantages and **eliminate the main legal and social risks** facing the project.
# The Stock and The "Sell-Out" Thesis
The stock trades in Canada (DMX.V) and Sweden. Over the last six years, it has risen from CAD 0.2 to CAD 1.40, valuing the company at around **$145 million** .
It is expected that with the amendment of the law on November 5, the company will be revalued .
The company's CEO has stated on numerous occasions that the ultimate goal is to **sell the property to someone who knows how to exploit it** (a "Major" ).
Without a PEA (Preliminary Economic Assessment) that clears up the technical risks, it's not possible to talk about a fair sale price. It is speculated that with a positive PEA and a favorable environment, the value could be **well above $1 billion**. What seems clear is that there is enormous potential for profit if the right circumstances arise.
And that's it. I hope this helps you understand the situation and serves as a starting point for your own thesis.
# 🤯 ...Wait, There's One More Thing.
On October 29, District Metals announced positive results from a study on its **Österkälen** license.
MobileMT results have identified a conductive anomaly (alum shale) **8 km long and up to 3.5 km wide**... with the *same geophysical signature* as Viken.
If confirmed, the company would add another Viken-sized deposit to its portfolio...

I currently have two biotechnology companies on my watchlist. Has anyone invested and or experience with this? liked to write
SELLAS Life Sciences Group
ATAI Life Sciences N.V.

Well I am personally waiting for a Bear market or a crash because the big money is always made when everyone's afraid. One thing that the Housing Crash in 2008 and the Dot Com Bubble have in common were that it were the low interest rates that led to the following events, and yes even I'm very convinced (atleast since the past 6-8 months atleast that a correction is due) I started back in 2022 so I did experience my share of the bullrun in 2023 but missed my opportunities during Covid (although I personally don't believe that was a bear market since we had a V shape recovery in a matter of 3-4 months).
I don't desire to short the markets at the top but, I've tended to book my Positionals with a 10-30% gain and not chasing triple digit gains. (something I wish to do with Smallcaps gradually accumulate post the correction and average out as and when required, since they'd take the hardest beating and even in present day they're more overvalued that the stable Bluechips).