aw .. missed this .. ;) 1 .. the easiest aspect

aw .. missed this ..

Quote:

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According to the order, Vandham routinely facilitated its broker-dealer customers' sales into the market by executing short sales throughout the day for its own account in the stocks being sold by these other firms on behalf of their customers. The order finds that Vandham later purchased shares in those stocks at a lower price from the other firms, also in its own account, to cover Vandham's short positions. For at least several thousand such short sales during the relevant period, Vandham failed to locate shares of those stocks that it could borrow. The order further finds that Vandham often published offers on OTC Link's electronic quotation service to sell shares it had purchased from its broker-dealer customers without first obtaining and reviewing required documents and information about the shares' issuers.

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