From June 2017 to the present, ACS Execution Services effected at least 10 million short sales to facilitate net trading by its broker-dealer clients without locating shares available for borrowing.
ACS failed to obtain locates for short sale orders as required by Rule 203(b)(J) of Regulation SHO:
As a result, ACS effected at least 10 million sho1t sales for its own account to facilitate short sale orders on a net basis without borrowing the securities, entering into a