The SEC authorized the DTCC to create a shadow clearing mechanism called the Obligation Warehouse so that participants like KCG could keep fails open and circumvent close out requirements of Rule 204. CLEARLY contrary to the Securities Act mandate to create a system of prompt and accurate settlement of securities transactions. The SEC fails data is for DTCC cleared trades ONLY. They know exactly the fails sitting in the non guaranteed OW. They just don’t disclose them. If Rule 204 was enforced consistently and for ALL participants, KCG would be out of business in a month.