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**Basic Description of Naked Short Selling, Failure to Deliver (FTD), and T+35 Rule**
**Introduction**
DTCC aims to improve efficiency using paperless, electronic systems, but the closed-loop system makes market manipulation activities like naked short selling possible.
**Regulation SHO**
Reg SHO aims to address naked short selling in the electronic clearing environment, but there are many loopholes that the SEC seems less concerned about.
**Naked short selling**
Market makers can engage in naked short selling without locating the stocks, which is allowed under Reg SHO regulations.
**Failure to deliver (FTD)**
Failure to locate the stocks for naked short selling within two days before settlement will result in FTD. Market makers can extend this up to 6 days.
**Regulatory loopholes and manipulation**
The SEC's rules are ambiguous and can be easily interpreted and manipulated, especially regarding Rule 203(a), the definition of "reasonable grounds", and the management of locate lists.
**DTCC's Stock Borrow Program**
Stock borrow programs can be used to conceal naked short selling, but there are abuse loopholes.
**Stock Clearing System and NSCC**
NSCC's Continuous Net Settlement System allows the creation of synthetic stocks, which market makers and hedge funds can exploit these loopholes.
**Summary**
The complexity of naked short selling, FTD, and the T+35 rule reflects the manipulation and regulatory challenges of the modern stock market.
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