SEC passes meaningless proxy voting rule sec.gov/news/press-rel… while ignoring Broadridge admission of tossing out votes to keep proxy count balanced b4 company sees: “Step 5:…a cap is put in place equal to total bank/broker position identified on record keeper’s file... 1/6
... This cap limits how many shares… [are]…applied to the official tabulation results.”
broadridge.com/article/vote-i… 2/6
Ignoring Feb 2021 letter from @SenToomey & @PatrickMcHenry on Proxy Plumbing. "Concerns about over-voting & verification of proxy votes have not been fully addressed. SEC should move forward to ensure integrity of proxy voting process." 3/6 [Opens PDF] banking.senate.gov/imo/media/doc/…
Ignoring 2021 Letter from Council of Institutional Investors "Proxy plumbing issues from 2010 have not been addressed" 4/6 [Opens PDF] sec.gov/comments/s7-14…
Ignoring 2018 Letter from Securities Transfer Association "5.9 million votes being discarded - - votes cast by investors who believed they were counted." 5/6 [Opens PDF] sec.gov/comments/4-725…
Sadly, it is not unusual for brokers to withhold voting materials from household investors when they only have enough real shares to cover their own & institutional accounts. Household accounts are 8x as likely to get tagged w/#FTR (phantom shares) than institutions. 6/6

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More from @SusanneTrimbath

Nov 8
Euro-Investors: Clearstream offers service to recycle (resubmit) failed trades. Trade is cancelled after 60 calendar-days unless broker tags-in within 45 days to restart the count. clearstream.com/clearstream-en…
This is similar to NSCC's "resubmit" service where tonight's fails are resubmitted for another chance at settlement tomorrow. I have not seen anything similar to the 60 calendar-day cancellation in the USA.
Recycle up to 60 days then cancel applies in all T2S countries: Austria Belgium Denmark Estonia Finland France Germany Greece Hungary Italy Latvia Lithuania Luxembourg Malta Netherlands Portugal Romania Slovak Republic Slovenia Spain Switzerland
Read 5 tweets
Nov 1
As you watch this tomorrow (Nov 2) and/or read about the Fed "setting interest rates," understand that the Fed does not directly control interest rates – trust me on this one, I edited briefing documents for a voting member of the #FOMC in the 1980s.
Dr.S Standard Lecture: Interest is the price of money – Fed tries to increase supply of money [buys bonds => securities in, money out] to decrease the price of money (interest rate). Conversely, Fed sells bonds to decrease supply of money which should increase interest rate.
I used to joke with the Senior Economist at FRB-SF that every time they missed an interest rate target (=>Fed Funds rate was completely outside the target range), they just moved the target range to include the new interest rate! It’s a math thing. 🤓 Like I said: they try to.
Read 6 tweets
Jun 27
After acknowledging moral hazard problem P107, House “Game Stopped” Report sets stage for routine broker bailouts because DTCC is “systemically important” enough for a bailout [FN601]. Ah, well. The more things change the more they stay the same, right? 1/6
P107 …represents moral hazard that undermines deterrent value of Excess Capital Premium charge [ECPC]. Specifically, firms may not be deterred from riskier trading practices because they [know ECPC] may be modified or waived, when risk of default is greatest. 2/6
P115 Policy Recommendation L: The DTCC, its subsidiary the NSCC, the SEC, and Congress should introduce an emergency backstop funding facility for NSCC member firms that provide emergency liquidity to the NSCC. 3/6
Read 6 tweets
Mar 4
When I set out to help investor and entrepreneurs, I believed the only possible solution was for Congress to act to force trade settlement. I believed that until I talked to Congress (Naked, Short and Greedy, Chapter 7). 1/4
Then I believed the only possible solution was in the courts. I believed that until I saw lawsuits by a multitude of public companies and investors fall apart under opposition from Wall Street’s self-regulatory rules (Chapter 9). 2/4
Next, I believed the only possible solution for investors and entrepreneurs being damaged by WS was through the criminal justice system. I believed that until I talked to the Department of Justice and the Federal Bureau of Investigation (Chapter 12). 3/4
Read 5 tweets
Nov 24, 2021
As promised in the Space last Friday, 5 Bullet Points for comments on S7-18-21 (SEC proposed Rule 10c-1). Real reform for securities lending must include:
(1) Notifying public about who is borrowing & lending shares (not just which company’s shares are borrowed or lent),
(2) Notifying retail investors that their shares are being lent, (because (a) they don't get to vote & (b) they don't get tax-qualified dividends),
(3) Sharing any revenue earned from lending their shares with retail investors,
(4) Eliminate “Onward Lending” completely (public companies & transfer agents have opposed this for decades),
(5) Require every loan to have a due date (not “if applicable”).
Read 5 tweets

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