SEC Failing To Deliver FTD Data, Intentionally?

After some apes noticed that the SEC FTD Data appears to be missing FTD data for Sept 20, I decided to analyze the FTD data to see if the data truly may be missing. Spoiler: Looks missing to me!

You may recall one of my prior DD's on FTDs about how FTD Data Is Rarely Late Meaning The Game Is Afoot. Basically, analyzing when something happens can be pretty interesting so I downloaded the FTD Data from the SEC [here], filtered out only the data for GameStop1, and then imported it into a spreadsheet using pipe ("|") as the delimiter. The SEC {SETTLEMENT DATES} are all in YYYYMMDD format which is quite easy to convert into a date for a spreadsheet2. Then, make a new column for every day in 2024. Of course, there won't be any FTD Data for weekends and market holidays. So, we can create a new column next to the days in 2024 for whether a particular {DATE} is a weekend or holiday3. Finally, one last bit of Spreadsheet Magic to check if a day in 2024 is MISSING from the list of days we have FTD data4.

As Roaring Kitty tweeted in May, here's a screenshot of what my spreadsheet looks like for May:

SUCCESS! We now have a column showing us every single date in 2024 that is MISSING FTD data! Set a filter for MISSING and you get a list of every day in 2024 so far that is MISSING FTD data5!

You may notice something interesting: August and September 2024 are MISSING a lot more data than earlier in the year (e.g., January to July). HALF THE LIST OF MISSING DATA DAYS are from August and September! IF missing days are simply errors, we'd expect them to be randomly and fairly evenly distributed. This is neither random nor evenly distributed so the missing data is clearly not erroneous. The other option is perhaps these days are missing because there's 0 FTDs on those days? Let's take a deeper look at these dates focusing on the time after Roaring Kitty's return in May 2024.

  • 5/24/2024 is the day when GameStop completed their first ATM offering this year. IF the ATM Offering provided enough share liquidity, it is possible that there were legitimately no FTDs on this date.
  • 5/30/2024 is odd because on the day before 5000 share blocks of CHWY started trading in the Dark Pool6. Also, a number of 5000 blocks of GME 6/21 $20 Call options were bought in the days leading up to this [SuperStonk]. Were there truly no FTDs on 5/30? Or was something going on here where the FTDs were too high to release the number publicly?
  • 6/11/2024 - 6/12/2024 is when GameStop completed their second ATM offering this year. IF the ATM Offering provided enough share liquidity, it is possible that there were legitimately no FTDs on this date.
  • 7/25/2024 is very spicy ๐ŸŒถ๏ธ odd because this is the day after We've Been Robbed! NO QUARTER! ๐Ÿšฉ when the NSCC punted on Clearing & Settling Roaring Kitty's 4M share purchase on June 10 resulting in GameStop apparently raising a Bloody Flag on July 24.
  • 7/31/2024 - 8/1/2024 are again very spicy ๐ŸŒถ๏ธ odd because these come at the end of the NSCC's settlement period for Roaring Kitty buying 9M shares of CHWY [SEC] where the NSCC appears to have punted on Clearing & Settling that trade too.
  • 8/15/2024 is weird, but I got nothing.
  • 8/20/2024 - 8/28/2024 is 5 of 7 trading days with MISSING FTD Data coinciding with a FINRA REX 068 Margin Call Cycle ending for someone after the NSCC declared their June 13 sale of 4M GME to Roaring Kitty [SuperStonk] and GameStop ending their restrictive credit facility [SuperStonk]
  • 9/4/2024 - 9/13/2024 is nearly 2 weeks (6 of 8 trading days) with MISSING FTD Data starting on the day GameStop did their share count [SEC] and coinciding with a FINRA REX 068 Margin Call Cycle from the 8/5 Japan Flash Crash.
  • 9/20 - 9/24 is 3 consecutive trading days with MISSING FTD Data starting on the last of a 60 calendar days (C60) can kick by any NSCC Managing Director from when the NSCC declared the June 13 sale of 4M GME to Roaring Kitty insolvent [SuperStonk]. Immediately after that can kick ended on 9/20, GameStop completed their third ATM Offering this year on 9/23. (Notably, CHWY also had 9.4M FTDs on 9/20 and completed a stock repurchase on 9/23, the same day as GME [SEC].)

Wut Mean?

Well, it's pretty clear that some missing FTD data may properly be 0 FTDs on those days because they align with GameStop ATM Offerings which likely provided enough share liquidity for shorts to cover (not close!).

Other missing FTD data, espeically from July onward, coincides with key events in the GameStop saga where there's absolutely no reason for there to be 0 FTDs when there should be huge demand for shares; which strongly suggests the FTD data is intentionally altered prior to dissemenation. You may recall my prior DD which found that the SEC delayed releasing FTD data because A Clearing House ๐Ÿชฆ and Big Banks Bankrupting Soon. Instead of delaying the release of data, which ChartExchange now tracks, the SEC's FTD data simply excludes sensitive information. "Transparency." Where the FOIA apes at???

I should also note these two statements by the SEC about their FTD data:

This text file contains the date, CUSIP numbers, ticker symbols, issuer name, price, and total number of fails-to-deliver (i.e., the balance level outstanding) recorded in the National Securities Clearing Corporation's ("NSCC") Continuous Net Settlement (CNS) system aggregated over all NSCC members. 

The SEC's FTD data represents shares that the NSCC's Continuous Net Settlement (CNS) system has failed to net settlement for. If you think of CNS as a juggler and share delivery obligations as balls in the air, the FTDs reported are the balls the juggler has dropped. It looks bad when there are too many balls on the ground (i.e., too many FTDs) so the SEC is just hiding them completely.

We cannot guarantee the accuracy of the data.

Q.E.D.

@ ChartExchange

Can you flag days where the FTD data is missing for people?

Endnotes

[1] grep "|GME|" [2024 FTD CSVs] >> 2024-GME.csv

[2] Simply use the following equation to convert a cell containing the SEC YYYYMMDD {SETTLEMENT DATE} into a date for the spreadsheet: =DATE(LEFT({SETTLEMENT DATE},4), MID({SETTLEMENT DATE},5,2), RIGHT({SETTLEMENT DATE},2))

[3] You can use the WEEKDAY function in a spreadsheet to determine if a {DATE} is a weekend and if you have a list of market holidays, you can see if a particular date is in that list. Something like this: =OR(WEEKDAY({DATE})=7,WEEKDAY({DATE})=1,NOT(ISNA(MATCH({DATE},{MARKET HOLIDAYS},0))))

MATCH checks if {DATE} is in a list of {MARKET HOLIDAYS}. If not, MATCH returns NA.

The OR function then checks if the {DATE} is a 1 (Sunday) OR 7 (Saturday) OR if the {DATE} was in the Holiday list (technically, NOT NA in the holiday list). The result of this OR equation is whether or not the {DATE} was a{WEEKEND_OR_HOLIDAY}when we should not expect FTD data.

[4] Simply use an equation like this for each of the {DATES} to flag {WEEKEND_OR_HOLIDAY}:

=IF({WEEKEND_OR_HOLIDAY},"",IF(ISNA(MATCH({DATE},{SETTLEMENT_DATES},0)),"MISSING",""))

[5] To make it easy for you, here are the dates in a text list for copy/paste in case you want to dig around: 2/2/2024, 2/5/2024, 2/28/2024, 3/4/2024, 3/12/2024, 3/22/2024, 4/1/2024, 5/24/2024, 5/30/2024, 6/11/2024, 6/12/2024, 7/25/2024, 7/31/2024, 8/1/2024, 8/15/2024, 8/20/2024, 8/21/2024, 8/23/2024, 8/27/2024, 8/28/2024, 9/4/2024, 9/5/2024, 9/6/2024, 9/9/2024, 9/12/2024, 9/13/2024, 9/20/2024, 9/23/2024, 9/24/2024

[6] A search on Unusual Whales shows 5k blocks ended 1/26/2024 and started up again on 5/29/2024.