>III. COMMITTEE STAFF FINDINGS
>**Key Finding #1:** Robinhood exhibited troubling business practices, inadequate risk
management, and a culture that prioritized growth above stability during the Meme Stock
>**Key Finding #2:** Broker-dealers facing the greatest operational and liquidity concerns took the
most expansive trading restrictions, although multiple broker-dealers introduced trading
restrictions for a variety of risk management reasons during the Meme Stock Market Event.
>**Key Finding #3:** Most of the firms the Committee spoke to do not have explicit plans to change
their policies for how they will meet their collateral requirements during extreme market
volatility or adopt trading restrictions when market volatility may warrant their introduction.
>**Key Finding #4:** The Depository Trust & Clearing Corporation (DTCC) waived $9.7 billion of
collateral deposit requirements on January 28, 2021. The DTCC lacks detailed, written policies
and procedures for waiver or modification of a "disincentive” charge it calculates for brokers
that are deemed to be undercapitalized and has regularly waived such charges during periods of
acute volatility in the two years before the Meme Stock Market Event
Revealing [6 member firms involved]( including Robinhood, in the DTCC total waived figure of $9.7B, a figure which was also newly released.
Math: $2.2B - $9.7B = $7.5B left after Robinhood's premium waiver is extracted means 5 more companies are left to divy up the $7.5B remainder.
So, even though we can't get exact figures, we can start doing averages on what each company could have been charged.
$7.5B ÷ 5 remaining members is ~1.5B on average each.
That means 5 other CEO were woken up at 3 in the morning just like Vlad with a massive deposite requirment.
**Citadel & Robinhood Worked Together**
>"Robinhood and Citadel Securities discussed ways to limit PFOF for one or both symbols.202
Citadel Securities wanted to make sure that Robinhood understood that the PFOF rebate rates
being calculated based upon Robinhood’s unique spread-based formula were untenable, especially
in the context of the unprecedented volatility and volume. As Citadel employees broached the
subject of limiting PFOF rebates within Robinhood, Jim Swartwout expressed frustration with the
concerns being relayed by the Citadel employee who managed the relationship with Robinhood."
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