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I don't buy the suggestion that DTCC deposit requirements left Robinhood and other brokers unable to facilitate all transactions. It is a backwards rationalization, trying to put technical reasons to a fear-driven decision.

First of all, they limited opening trades for all accounts, not just accounts buying on margin or with unsettled funds. If you have a cash account and you buy a stock, your broker has plenty of time (2days) and plenty of funds (all of them) to clear your trade.

Secondly, many brokerages only blocked options transactions. These don't clear through DTCC at all. They clear through OCC and net purchases of options actually capitalize the clearinghouse and can in some cases actually be advantageous to the broker by getting their accounts long premium (if the broker is net short premium, the OCC charges them more).

It's more likely that the brokerages didn't have enough staff to reconcile the trades, or that Robinhood's fake margin accounts (Robinhood Instant) left them in a position where they had to choose between telling people that they have to wait for funds to settle, or limiting trades.

Any brokerage that limits trading in an asset for which the exchanges and clearinghouses are functional is harming its customers by preventing their market access. Weird hand-wavey apologetics about the DTCC or OCC don't explain why the retail brokerages had to limit trading in cash accounts.




> your broker has plenty of time (2days) and plenty of funds (all of them) to clear your trade

I think you’re thinking about it wrong. All brokers contribute to this posted collateral and those funds, collectively, serve as a fund of mutual insurance in the event of a failure or near-failure of a participant. These are not "partial payment of customer trades, with the rest to come later".

In order to prevent customers from being affected by that near-failure, the clearinghouse first goes to that struggling broker and then to this mutual insurance fund. That is the reason why this must be funded with broker funds rather than customer funds, so the fact that you 100% paid for your shares doesn’t mean that the broker has “all of the funds” required because they can’t use your money to post this. (Otherwise “to protect customers” is not accomplished.)


Brokers are not allowed to touch client money to submit the deposit. That the purchases are settled cash on the user's account makes no difference, because none of that money Robinhood could use to clear the deposit.


But it’s not client money the second the trade executes?


It's client money until the trade settles at T+2, at which point it's the counterparty's money. It's never Robinhood's money (unless they're the counterparty, but I don't believe they do propriatary trading)


At what point does the client's money belong to Robinhood? You're not buying stocks from Robinhood.


Robinhood is on the hook to do their part in settling the trade and delivering the shares to their client and cash to the seller.

Obviously once funds are used to execute a trade, they are no longer client funds. It seems obvious that the cash at that moment would be held separately as the shares settle. That's discretely identifiable hard cash that is fully funding that specific share purchase.

I completely grok the various ways that cash that "looks like" it's in the account might not be; deposits that haven't actually cleared, prior trades that haven't actually settled.. and in those cases the brokerage is actually extending credit to their client, and that credit can run dry.

But if I have hard cash and a trade executes, that cash is gone from the account. The counterparty risk at that point is the shares not being delivered, which seems to me like it would be collateral that the seller needs to be posting to DTCC (likely DTC already holds the shares). The buyer needs to show they have the hard cash, and they can easily do that.

I guess I can't get around the fact that if the purchase is fully funded with hard cash that's in the account, that is cleared cash that can be sent off to DTCC/NSCC during the end-of-day settlement via FedWire.


I think the margin stuff is pretty much a red herring. The customer's cash doesn't belong to Robinhood. Robinhood is required to provide its own cash as collateral, because it's ensuring the market against itself. Those collateral rules aren't just for margin purchases.

Would love to be corrected here if I'm wrong, but I'm not sure margin has really much to do with what's going on, and it seems to be most of what we're talking about.


Robinhood has finite working capital and credit limits.

The more of their capital consumed by margin loans, the less available for collateral.


Robinhood Instant means that a customer doesn't necessarily need to have settled funds to trade.

https://robinhood.com/us/en/support/articles/deposit-money-i...

They call this a "margin" account but FINRA has rules about how margin accounts work. Minimum maintenance is 25% for long shares, and minimum equity is $2000.

https://www.finra.org/rules-guidance/rulebooks/finra-rules/4...

I could envision how Robinhood's margin practices and Robinhood Instant contributed greatly to the need to draw on credit lines and raise additional funds from investors.


I think we're talking past each other. I'm saying that, according to the rules, even if Robinhood had absolutely no margin buying whatsoever, they'd still have substantially the same collateral problem. They can't use customer funds for DTCC collateral.


I believe this is the correct understanding, with the minor explicit callout that every dollar RH had to use to cover pre-cleared ACH deposits was a dollar they couldn't use to put towards backing their DTCC collateral.

So in one way, the influx of new users and new inbound money could not have come at a worse time, even though I also believe it likely was rather inconsequential in comparison to the DTCC requirements.


> even if Robinhood had absolutely no margin buying whatsoever, they'd still have substantially the same collateral problem

They'd have a less concentrated position in GME, a smaller CNS long, and lower peak net settlement debits. All of those factors affect capital commitments. They also wouldn't have to commit their own capital for Robinhood Instant accounts with customer check/ACH deposits that haven't cleared. Currently, Robinhood Instant means that Robinhood uses up to $1k of its own funds per account to clear trades...not DTCC collateral, but rather just to pay for the trade.

In the absence of margin, Robinhood doesn't have a collateral problem in the sense of effecting transactions that may not clear. Rather, it has a liquidity problem. Big difference.

The risk to Robinhood from GME buying in margin accounts is that they would have a very large net long as a firm, and then one day the stock gaps down so quickly -- perhaps overnight -- that there is no time/opportunity to close out margined positions before they lose more than their accounts' total equity. That could leave Robinhood holding the bag on 75% of the loss assuming minimum maintenance margin.

That's why I don't believe margin to be a red herring. It directly and indirectly affects the amount of the required deposit and the clearing obligations of the firm, and also imposes a very large risk upon Robinhood in the event of a scenario where GME closes in the after-hours session at $300 on a Friday and then reopens at $0.40 on Monday morning because the company filed for bankruptcy (just an example). That scenario in turn reduces the likelihood that Robinhood can borrow from banks and investors to infuse itself with the cash required to keep its business running.

Someone else posted an article saying that additional collateral across all firms due to the r/WSB squeeze is a bit less than $8B according to a DTCC spokesman. Not sure how much of that is attributable to Robinhood. That sounds like a lot of money but it's really not, in the world of financial institutions -- especially in today's cash-happy low-rates environment. To put it in perspective, Melvin Cap got $2.75B overnight, from two people.

My own personal gripe about this whole thing is that the way Robinhood carried out its business was chiefly damaging to its own customers. I also believe they shouldn't be allowed to offer "Robinhood Instant" because it doesn't appear to line up with federal requirements for margin accounts.


I think--like most outsiders trying to have a technical discussion--you can peel back the onion only so many layers.

A true insider would alternatively laugh or cringe at our crude analogies and simplifications of what's really happening inside the factory.


Yeah, I'm trying to use more question marks and hedging "as I understand its" here. I've pentested huge clearing systems before. But I'm not going to lie and say I understood what the hell they were doing (also, the people at those firms made fun of clearing as the most boring conceivable stuff to look at).

But (1) lots of experts keep saying that Robinhood can't use customer cash as collateral to DTCC, and (2) DTCC's published rules seem to say that Robinhood owes collateral margin or not.

So like, I'm willing to bet that the margin stuff is a red herring, but I'm not willing to WSB-bet it.


The margin accounts seem to be a small part of it but they do tie up RH's cash further thus limiting what they have available for collateral.


This is right; in fact the article says "this is not about margin accounts".


You say it's bizarre, but apparently the regulations are written so that customer funds can't be used until the trade settles.

Going by what you think is reasonable isn't going to answer the legal question.


Would you mind quoting that part of "the regulations," or at least linking to them and giving a general nudge toward the relevant section?


The whole premise of client asset segregation is that failure of the broker should not put the assets of a client in jeopardy. This isn't a technical detail of "the regulations", it's the entire foundational premise.

The trade is not "done" until it settles. As discussed throughout, that's T+2. Prior to settlement, the trade can fail (e.g. your counterparty turns out not to have the money/stock to fund their side of the trade).

If you really want to read the detail, it's called Rule 15c3-3.


15c3-3 does not say that a broker can not use client funds to purchase securities for the client that the client is trying to buy.

It says the broker can’t use client funds to purchase securities for proprietary trading.

Everyone has totally misread the rule and then is stating a total falsehood as if it’s unequivocal truth. It’s maddening.

> The Commission adopted Rule 15c3-3 in 1972, in part, to ensure that a broker-dealer in possession of customers' funds either deployed those funds “in safe areas of the broker-dealer's business related to servicing its customers” or, if not deployed in such areas, deposited the funds in a reserve bank account to prevent commingling of customer and firm funds.[7] Rule 15c3-3 requires a broker-dealer to calculate what amount, if any, it must deposit on behalf of customers in the reserve bank account, entitled “Special Reserve Bank Account for the Exclusive Benefit of Customers” (“Reserve Bank Account”), under the formula set forth in Rule 15c3-3a (“Reserve Formula”).[8] Generally, the Reserve Formula requires a broker-dealer to calculate any amounts it owes its customers and the amount of funds generated through the use of customer securities, called credits, and compare this amount to any amounts its customers owe it, called debits.[9] If credits exceed customer debits, the broker-dealer must deposit that net amount in the Reserve Bank Account.[10]

https://www.federalregister.gov/documents/2004/09/07/04-2018...

> Possession and Control Monitoring is related to SEC rule 15c3-3 - The Customer Protection Rule. The Customer Protection Rule prohibits a brokerage firm from commingling fully paid for customer securities with non-fully paid for customer securities and/or firm securities.

> When a client of the firm purchases securities through the firm and pays for those securities in full, the firm must "lock-up" or "segregate" those securities for the protection of the client. The segregation of fully paid for customer securities protects those client owned securities from the firm's creditors in the event that the firm can no longer continue as a going concern - that is, the firm goes belly up.

> SEC rule 15c3-3 also prevents the brokerage firm from using full paid for segregated shares to satisfy any delivery commitments that might result from the firm's trading activities. If, for whatever reason, the firm does use segregated customer shares to satisfy a firm delivery a 'SEG Violation' or Possession and Control violation occurs.

http://brokerage101.com/opscntl.html

> The reserve formula calculation is performed weekly to identify customer related payables and receivables. If the calculation results in a net payable to customer, the broker-dealer is required to reserve this amount in a special reserve bank account. This special reserve bank account is for the exclusive benefit of customers and funds can only be withdrawn with the support of an updated reserve formula calculation. In theory, on the date the reserve formula is calculated, combining the securities held in possession or control plus the funds included in the reserve formula should equal the amount the broker- dealer owes to the customer.

https://www2.deloitte.com/content/dam/Deloitte/global/Docume...

> Rule 15c3-3 prohibits use of customer property to support non-customer activities.

https://www.sec.gov/rules/final/34-50295.htm


This is a long series of citations that seems on its face to confirm that broker-dealers can't use customer funds to post DTCC collateral.


Where do you get that from?

Everything in the rule is about not using customer funds for proprietary purposes. Not co-mingling customer and brokerage funds. Meaning the brokerage can’t make their own trades with customer money.

There isn’t a single word against using customer funds to purchase customer shares.

It’s a rule against using customer funds for non-customer activities.

If anything the problem that Robinhood ran up against was net capital requirements under 15c3-1.


It seems that clearinghouse collateral is considered "firm overhead"?


Yes. I don't really understand what is being argued here.

There are three stages; execution, clearing and settlement.

Execution is the formation of the legal-binding agreement, e.g. a contract to exchange money for stock. For these cases, this is happening via matching on an exchange between a buyer and a seller. If the time of the trade is T, then happens at T+0.

Clearing is the paperwork activity that takes place after execution that include the due diligence steps of making sure that trades match, as well as other stuff that can reduce the amount of settlement activity. This happens in the period from T+delta through T+2-delta.

Settlement is the actual exchange, and is the point at which legal ownership of the stock changes. This happens at T+2.

It is obviously true that the brokerage uses client money for settlement; otherwise how would the broker ever fund any trades by its clients?

Is also obviously true that prior to the moment of settlement the client money is ... the client money, and subject to segregation. In other words, from the broker perspective, it's always client money until it's off their books.

The time when the NSCC wants to see adequate collateral is exactly during the clearing period, when the actual counterparty risk exists. That collateral absolutely cannot be from client money due to the segregation rules because the whole purpose of the collateral is to reduce the risk of a broker failure causing clients to lose money.

RH's collateral requirements blew up because some substantial proportion of their clientele was attempting to go long GME during a period of vast price volatility, and the NSCC's procedure for determining those requirements takes into account primarily the size of the net long position and the volatility for each member.

Net result: RH has to go raise capital in a hurry; RH stops its clients from going any further long GME.


So I'd say the truth came out in an interview late Sunday evening between Elon Musk and Robinhood CEO Vlad Tenev. [1]

> Tenev explained that while he was sleeping, at 3:30 a.m. PT on Thursday, Robinhood's operations team received a file from the National Securities Clearing Corporation (NSCC) that as a clearing broker, Robinhood Securities needed to put up around $3 billion "an order of magnitude more than what it typically is."

> So, it was unprecedented activity. I don't have the full context about what was going on, what's going on in the NSCC to make these calculations," Tenev added — prompting Musk to joke if someone was “holding you hostage right now.”

> Tenev said that after putting their heads together and calling the higher-ups at the NSCC, they got that figure down to $1.4 billion, from the initial $3 billion. "We were making some progress, right, but still a higher number," he added.

> Next, Tenev said they had to explain how to "manage risk in these symbols" by restricting activity in the volatile stocks. After that, the NSCC said the charges on the deposit were $700 million, which Robinhood "paid promptly."

You don't even have to read between the lines here. Robinhood isn't the problem here. Massive long retail demand is crushing shorts, which is potentially opening the clearing houses to multi-billion dollar losses. The way to stem the losses is to stem buying pressure and get the stock to come down.

So call up Robinhood and demand $3 billion in collateral (an order of magnitude higher than the day before) unless they stop the buying pressure on the shares. When Robinhood agreed to limit buying, the NSCC was willing to drop the collateral requirement to $700 million.

This isn't about a share-for-share clearing / transaction cost for each buy order entered. Those buy orders are cash funded and zero risk for Robinhood and zero risk to NSCC / DTCC. This is about extorting Robinhood to stave off the bankruptcy and subsequent contagion of a 140% short interest on a stock that's gone up 70x in just a few months.

Look, I agree that Robinhood can't use customer funds to pay extortion demands from the clearing houses. My point is that Robinhood clearing fully cash-paid buy orders does not incur additional clearing costs to Robinhood. It's not a per-order transaction fee. It's a slush fund which is used to pad against defaults.

> "Now, why is that so high? Like this seems like, it sounds like an unprecedented increase in demand for capital. What formula did they use to calculate that?" Musk asked.

> To contextualize the number, the app's CEO noted that RobinHood had raised about $2 billion in total venture funding. He added that the formula was “not fully transparent” and “not publicly shared.”

[1] - https://www.msn.com/en-us/money/savingandinvesting/spill-the...


I'm sorry, but you just conceded the whole discussion (turns out: it was definitely clearing collateral calls!) but then moved the goalposts to a conspiracy in which the clearinghouses were protecting the shorts.


A lot of people are claiming “customer funds have to be segregated” and that “funds can’t be used to actually buy the security and are not released from the customer account until the trade settles”.

I think these are massive oversimplifications to the point of being useless or outright false.

I suppose if you wanted to learn a little bit about how the regulations are actually written, you could start here:

https://www.finra.org/sites/default/files/SEA.Rule_.15c3-3.p...

These are just some of the requirements that brokers have to “reduce securities to possession or control” for both fully-paid or excess margin securities.

Here’s my (mostly uneducated) opinion on what is really happening. It has roughly nothing to do with Robinhood not being able to execute Buy orders because they couldn’t post the funds required. Because fully-paid securities (non-margin) are paid for with customer funds, not floated by the broker while they settle.

The problem was that too many shares have been lended out to short sellers out from under long positions that are now trying to sell.

The hedge funds that borrowed and sold those shares simply don’t have the cash or credit to buy the shares back at the current market price that the rightful owner has rightfully now sold. Failing that the broker needs to find someone else willing the lend a share the the hedge fund. And who would want to lend a share of GME to an insolvent short seller?!

So there is a deficiency, but the deficiency is because of hedge funds which are now $30B underwater while unrelated parties are trying to sell shares that have already been sold.

Yes, this is a long way of saying there’s a short squeeze. But you know the saying “owe the bank $1 million you can’t pay, that’s bad news for you. Owe the bank $100 million you can’t pay, that’s bad news for the bank!”

It’s a game of musical shares. The brokers that let the hedge funds load up on 140% short interest now need to either force-liquidate the hedge fund shorts to get back the share that’s being traded and needs to be delivered to Robinhood, or they need to find someone else to borrow the share from.

When the broker fails to deliver the share at the time the original holder sells it, the broker is now on the hook for any price movement that occurs until they can deliver. Which of course the hedge fund can’t afford, so it’s lose-lose.

In the end Robinhood disabled the buy button because all the shares being sold have been loaned out and shorted, there’s not enough shares available to borrow, and the hedge funds are way past bankruptcy at this point and hoping for some massive price reversal or else they take a lot of people down with them.

The counterparty risks at this point are extreme. It’s not Robinhood that’s the problem, it’s the people selling Robinhood shares that they can’t actually show a clear title on. I think what Robinhood is worried about mostly at this point is contagion when the hedge funds holding 140% short interest can’t afford the $30B bill.


I'm really skeptical that robinhood shut down buys because they were the ones worried about counterparty risk. That's kinda out of character. And then extended that concern to 50 other stocks.


There’s zero risk to Robinhood to settle a full-cash Buy of a security, except for counter-party risk not being able to deliver the shares free and clear.

Lack of truly real available GME shares are literally the whole issue at hand here, since literally more than all of them have actually been loaned to the Hedges to short.

The funds are deposited and under the full control of Robinhood.

This theory that Robinhood has to match their customer fully cleared funds with their own dollars, which can’t be backed by the customer funds, in order to actually take delivery of the shares and only then can the customer account funds be debited.... It’s been repeated constantly without evidence, and I’d really like to see the evidence.


You're saying this, but the rules (which are convoluted) appear to require fund segregation, and, moreover, when MF Global was accused of doing what you're talking about, it was a major NYT and WSJ story.

http://m.futuresmag.com/2011/12/28/mf-global-may-have-sent-c...


What MF Global did was totally different;

> The story states that a London clearinghouse forced MF Global to pay roughly $300 million to back some of its bond holdings during its last week.

There's a mountain of difference between sending customer money to purchase customer's own securities, versus raiding customer accounts to pay a margin call against your own bond holdings.

You cannot raid customer funds to pay for proprietary (broker's own) activity. Of course using customer own funds to pay for customer's own orders is not restricted. There's nothing to collateralize for a fully cash funded share purchase. Collateral can only possibly be an issue if the customer is trading on margin.



Can you go into more detail about your read of 15c3-3 allowing Robinhood to post customer funds to satisfy its clearing obligations with DTCC?


It's client money until it settles.


Assuming this is true, what the brokerage needs to do is take a loan against the settled cash they are already holding in escrow for ~24 hours.

Suppose a 3% interest rate (which seems high for guaranteed cleared funds), $1 billion for 24 hours is $82,000.


The Broker isn't allowed to borrow against client money either - it's client money, partitioned off from the broker's fungible funds, and not the Broker's to offer as collateral.

But debt is the natural answer, and Robinhood did get as much in loans as they can[0].

[0]https://finance.yahoo.com/news/robinhood-said-draw-credit-li...


>what the brokerage needs to do is take a loan against the settled cash they are already holding in escrow for ~24 hours.

and that's exactly what they did. On thursday night they secured a $1B loan.


That's not exactly what they did. What they did was to get $1B in funding against other assets that are actually theirs.

Just because your house is worth $1M doesn't mean that I (being "not you") can go get a mortgage pledging your house as collateral.


If you think brokers are not allowed to use a customer funds to settle that customer's transactions, I've got news for you buddy.


Of course they are allowed to use it to _settle_, but not for the clearing fund deposit.


> First of all, they limited opening trades for all accounts, not just accounts buying on margin or with unsettled funds.

RobinHood’s UX was built around the concept of hiding margin details from clients. All Robinhood accounts are margin accounts by default. Inbound funds transfers give people margin buying abilities before the trades arrive.

Is it really so hard to believe that they hadn’t pre-planned the ability to limit margin purchases on a single stock? This is an unprecedented event and it happened very, very fast.

Robinhood likely only had a few options to roll out immediately. Let’s not pretend they could have reworked their trading platform, tested and deployed the changes, and implemented the action in a matter of hours.


If this was the case, why not just provide an honest explanation rather than “we’re restricting this for your own good”


No company likes to say "our clearinghouse doesn't trust us to settle our accounts". It makes them look unstable... as they probably are. I bet you, RH has been handing out margin the same way mortgage sellers handed out loans in 2007.


If they're not willing to be honest with their customers, I'm not willing to sympathize with them when their lies result in conspiracy theories. They made their bed.


Yeah, I don't sympathize with them either, but I think the conspiracy theories are probably false.


What they did was still blatant market manipulation, even if the conspiracy theories are all wrong and it was unintentional. That alone warrants a serious investigation and probably the introduction of some new market regulations.


Sure, but people should probably know the truth about it being incompetence or a conspiracy to save GME shorts before they decide to plow even more money into the trade.


Yes RH is terrible.


LOL but RH is known to be pretty unstable...

"Redditors in the irony-poisoned Wall Street Bets (r/wallstreetbets) community discovered an exploit in the investing app Robinhood they’ve named “infinite leverage” that enables them to lose huge sums of money at record speeds."

https://www.vice.com/en/article/gyz9kj/a-robinhood-exploit-l...


Because the honest explanation was that they were near insolvent for a period.


> Is it really so hard to believe that they hadn’t pre-planned the ability to limit margin purchases on a single stock?

Yes, this is impossible to believe. Different stocks already have different margin requirements. Turning off margin trading for specific stocks is a fundamental system requirement.


I think all these margin discussions are a red herring. The clearinghouse requirements are based on the total number of shares sold, not the total sold on margin. As I understand it, clearing is mutual insurance against a disaster at the brokerage, not against customers randomly defaulting.


> If you have a cash account and you buy a stock, your broker has plenty of time (2days) and plenty of funds (all of them) to clear your trade.

If they have two days to pay, DTCC is taking on some counterparty risk. Isn't that reason enough for DTCC to increase the deposit requirements when they see risk increasing? (Not a rhetorical question, you seem to know what you're talking about so I am curious what the answer is.)


That is true, and maybe most likely what’s happened.

Just realized that DTCC changing the deposit requirements seems completely non-transparent and arbitrary (I agree it was a plausible reason in this case), abs could be used to help their friends in hedge funds that had shorted, out of someone paid them to do this.

The fundamental problem is that the stock market has substantial different rules, for example see after hours trading, which can be used to take margins away from unprofessional investors.


> Just realized that DTCC changing the deposit requirements seems completely non-transparent and arbitrary

There’s a difference between something being so esoteric that most people don’t know about it, and being non-transparent. As the article points out, the deposit requirements follow a known formula, it’s just one that most of us had never heard of before all this.


Thanks, I didn't catch that part.


The purpose of a clearinghouse is to manage that counterparty risk prior to settlement, and ensure that settlement occurs smoothly. Some clearinghouses like OCC carry counterparty risk throughout the life of a trade.

The counterparty in question is the clearing member, ie Robinhood. If the trade is fully cash-secured then there is no risk that Robinhood will go under because it has 100% of the cash required to make good on the trade (assuming they still make enough from PFOF to cover their operating costs for a couple of days.) And for existing margin accounts, they just have to continue the practice of aggressively closing positions that fall below maintenance margin.


The NSCC formulas for this (I assume these are the relevant ones and if not that they're representative) are published. You can just go read them. I don't see where they say "if trades are made with customer cash and not on margin you don't have to account for them in the equity group collateral requirement". That also wouldn't make much sense; the clearinghouse protects participating firms from each other, not just from their customers.


Actually, the Clearing Fund Formula accounts for Margin Requirement Differential, so margin is indeed a component of the amount posted.

More importantly, cash requirement effectively reduces the amount of leverage that customers are able to use, and that means (A) no additional firm capital needs to be lent for purchases of GME or whatever other stock, and (B) margin-account customers trade less on a given amount of their own capital.

Are you suggesting that Robinhood would be required by Procedure XV to post more than $1 for every $1 of GME stock that a customer buys in a cash account?


I'm not sure I follow why the future actions of Robinhood customers matter. They've executed the number of trades they've executed, DTCC raises the collateral requirement for meme stocks, and now they're on the hook, whether stocks were purchased on margin (implicitly or otherwise) or not. You've got the rules in front of you. They seem to plainly say that Robinhood has to put up collateral regardless of whether margin is involved.

Again, I think the margin stuff is mostly a red herring?


I think the suggestion is that RH is required to post $1 even for cash buys, not just 0.02 or whatever it was before.


Comments that start with saying "I don't buy" the real-world non-simple explanation, even in the face of mountains of real world evidence, are not in the spirit of any site that pretends to be some kind of better place.

Conspiracy fantasies should be moderated down by the administrators. "Wide eyed curiosity" comes second to pragmatism, realism, lack of narcissism and entitlement.


It’s scary how much conspiratorial thinking is gaining traction in the GameStop story.

Despite the narratives about people buying GameStop for altruistic purposes or for sticking it to Wall Street, it’s obvious that most people bought because they were told the trade couldn’t fail and this was an easy way to double their money (or more).

When it doesn’t work out, I’m worried that people will reach for more conspiracy theories instead of realizing that the latest GME buyers were always guaranteed losses.


When I get explanations like “you can’t buy or sell for your own good” on a funded account without leverage, at a time where the odds of money were sky high, it does seem fishy. People on WSB have been YOLOing entire accounts to zero for months, where was the concern when people were losing money? Why the concern when they are actually making money?

Also, if there is a good regulatory explanation, why not just give that, instead of thin statements like “we’re blocking these trades for your own good.” I’m open to reasonable explanations with evidence.


The messaging was not forthcoming, I’ll grant you that.

But they are actually correct if you take a step back. Protecting the DTCC protects all brokers and thus in turn protects their users.

The regulations and the practices followed in the industry are to protect against against real scenarios which can lead to brokers collapsing and investor funds being decimated.

Maybe it would have looked better had robinhood come out and said “we don’t have enough liquidity”, though that’s still not a reassuring message for their users.


I remember the MMM ponzi scheme that was in a bunch of countries including Nigeria. When these things go south people always need an outlet to blame for denying them their free money they thought was coming and better if its a third party and not themselves or whoever duped them into investing. People were furious at editorials or government officials trying to dissuade others which may or may not have brought it to an end. Here its going to be the brokers fault for not being able to let people open more positions, otherwise it certainly would have kept going up and certainly at some point there would have been a price they were willing to sell at.


It's puzzling that people find it surprising that the situation caused speculation and "conspiracy theories."

It's frustrating that the phrase "conspiracy theory" is used as a way to dismiss skepticism. I hear more and more hand-wringing that conspiracy theories needs to somehow be addressed.

And it's annoying that given how complex the situation is, and how little transparency in the market there is, we think that one narrative by authorities should be taken at face value.

If you truly dislike conspiratorial thinking, then it seems the best possible reaction is to reply calmly explaining to the conspiratorialists what happened and buttressing counter-claims of the skepticism where it exists.


Common, I may not know enough about the stock market to be opinionated about this case in particular, but when literally billions are at stake, conspiracies about mild collusion between brokers and market manipulation are really not that far-fetched.


I like how you criticise the above comment for saying "I don't buy" based on high-minded notion of better spirit of discussion, and then in your second paragraph imply it's a "conspiracy fantasy".

Bonus points for your completely failure to address the arguments of the comment.


It's not my job to teach everyone about trading operations. I am alarmed at the prevalence of anger founded on willful ignorance, on this site. I don't have an obligation to refute every dumb angry post tit for tat. I am not even trying to be "right" I rather want to encourage people not to fall prey to the temptation of thinking that you can simply scrunch up your face and decide to "not buy" a narrative simply because you cannot be bothered to be well informed.


To be honest it just sounds like you're one of those people who goes on social media, makes a claim, then when someone asks for evidence you just say "look it up". Unless you have something to contribute other than smug comments that amount to "look at these dumb plebs who know nothing about the market", then please stop posting FUD.


A Soros-owned space laser is a conspiracy theory. Citadel forcing Robinhood to disable buys due to their massive short position is not.

I feel that many people are lumping hypotheses into the conspiratorial bucket because of Qanon and current events. Are all skeptics conspiracy theorists?


The space laser is certainly more outlandish, but both are fundamentally the same. They both posit (contra all the available evidence!) that sinister forces are behind something in the world that you feel has gone wrong.


There's no difference between conspiracy and hypothesis.


You mean "conspiracy theory" and "hypothesis". And yes, there fundamentally is a difference between theory and hypothesis:

https://www.merriam-webster.com/words-at-play/difference-bet...


> Outside of scientific reasoning, "theory" and "hypothesis" are often used interchangeably, and "theory' can unfortunately be interpreted to mean "less sound" or "lightly speculated."


I read that "cash accounts" don't really exist from the clearing perspective, because the broker can't counts cash accounts as part of its collateral.

Cash accounts (which is just a margin account with 100% collateral in cash) protect the broken against client default, but don't protect the clearinghouse from broker default. It's an opaque API wrapper, in programmer language.


For cash accounts, the broker already has settled cash when the trade is made, and can immediately post that cash to the clearinghouse.


The broker cannot use customer funds to post a broker obligation.


The broker would be using customer funds to clear a customer trade.


Of course they'd do that when it comes time to actually fund the trade. That's not what Robinhood's limitation was and not the subject of this article. The funds in question required to be posted to DTCC are a broker responsibility to serve as mutual insurance wherein the risk of a broker failing are shared among the brokers in some proportion to the volume and risk that they represent. These must be posted using broker funds (obviously, you can't protect customers from things outside their control by pledging customer money to be used in the event of a default).


How, pray tell, do you think a broker actually funds an unsettled obligation on a cash-secured customer trade?


At this point, I wonder if you’re willfully not understanding the difference between customer funds for settlement and DTCC broker deposits to ensure an additional layer of customer protection/confidence, possibly because you think it shouldn’t be necessary.

In some ways it’s worse than the Chesterton’s Fence parable. You don’t see the point of the fence, so you pretend that it already doesn’t exist.

It seems perfectly fair to ask why this required broker deposit exists. It seems way less productive to ask whether it exists or to pretend it doesn’t.


Perhaps the part that you're missing is that in addition to margin accounts, Robinhood also has accounts that are able to trade up to 1k before they are funded (that is to say, before the deposits clear). So Robinhood has to lay out its own money to clear those trades, as well as traditional margin trades where the customer has settled equity but the brokerage also carries risk.

BTW, I don't know what that parable is but your invocation of it seems like a rather complex way of telling me that you think I'm being disingenuous.


Not as collateral, it has to be the broker own funds. (It's a protection against brokers failing)


DTCC raised collateral requirements for GME from 2% to 100%.


Is that documented somewhere? I absolutely believe it, I'm just curious.


Robinhood CEO said on an interview with Musk that collateral went overnight from 300m to 3b (which they were later able to negotiate down to 700m by stopping buy orders)


Source?


While DTCC did not publicly confirm the amount, it did confirm that capital requirements were raised January 28. Given that numerous participants have publicly stated it was to 100%, that seems likely.

https://www.bloombergquint.com/quicktakes/what-s-the-dtcc-an...


But but but that's not market manipulation, that's just one company doing a normal thing in the normal course of business…

I'm sure it had nothing to do with GME.


It had lots to do with GME in that GME was the source of the risk (because of its through the roof volatility) that the DTCC was protecting against. But if your implication is that the DTCC has a dog in that fight you are way off base - they exist several layers below hedge funds in the trading stack and have nothing to do with each other, in fact I'd be willing to bet Gabe Plotkin couldn't even tell you what DTCC stands for.




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