SEC Follow Up Exhibits Part C SEC_OEA_FCIC_001760-2501

Chart 1
Form SH Daily Volume Compared to Exchange Reported Short Volume
November 2008 - February 2009
This chart provides a detailed measure of the amount of short-selling activity captured through Form SH. For each reported security, on each of 80 days
between 11/3/08 and
2/27/09, we calculate the total volume of short selling on Form SH and the total volume of short selling based on data provided by NYSE, FINRA, and NASDAQ. An "observation"
in this chart reflects the volume of short selling for a particular security, on a particular day. The chart indicates that for 12,250 observations, there was
no short selling reported
by either the exchanges or by Form SH filers. For 77,395 observations, there was no volume reported by Form SH filers, but there was some short activity
reported by the
exchanges. On the far right side of the chart, there were 1,276 observations where Form SH filers reported short volume was between 95% and 100% of the exchange reported
short volume. Finally, there were 19,174 observations where Form SH reported short volume exceeded the short volume reported by the exchanges.
90,000
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For Internal SEC Discussion Purposes Only
Form SH Volume
%
77,395
80,000
334,515
# Days
84.37%
Mean
70,000
4188.11%
STD
57,017
60,000
0.00%
Min
0.00%
P 25
50,000
7.78%
Median
28.03%
40,000
34,150
1392741.01%
P 75
Max
25,923
30,000
19,174
19,997
15,754 12,841 10,786 8,937 7,546 6,300 5,220 4,316 3,522 3,059 2,471 2,129 1,729 1,511 1,292 1,276
20,000
12,250
Observations (Number of Days for each security)
10,000
0
100+
95-100
90-95
85-90
80-85
75-80
70-75
65-70
60-65
55-60
50-55
45-50
40-45
35-40
30-35
25-30
20-25
15-20
10-15
5-10
>0 - 5
0
None
Form SH Reported Volume as a % of Total Short Volume
Page 8
SEC_OEA_FCIC_001880