Exhibit 38 (Dkt. 567-38, S.D. Fla.)
Summary
Exhibit 38 (Document 567-38) in Case 1:21-md-02989-CMA, entered on the FLSD docket June 7, 2023, is a 16-page printout of a document provided in native format, RHMDL00047970, tabulating trade limits or restrictions by symbol with the date and timestamp when effective and when removed, the approver and the reason. The table records RHS margin requirement increases approved by Jim Swartwout, President and Chief Operating Officer of RHS, for risk management purposes given extreme market volatility, beginning with GME on 2021-01-25, when the initial margin requirement was set to 50% and the maintenance margin requirement to 25%, and EXPR on 2021-01-26 at 68% and 60%. Later rows record quantity limits on certain symbols' options and equities from January 29, 2021 through February 4, 2021 to ensure RHS would continue to meet NSCC's deposit requirements.
Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used
- Date
- 2023-06-07
Cite this document
“Exhibit 38 (Dkt. 567-38).”
Original at archive.org, dated 2023-06-07. Archived at Pandemic Darlings, https://pandemicdarlings.com/source-documents/2023-06-07-covid-era-misc-0d4b79c6-1/
, SHA-256 0d4b79c6eac9bc13e808268be7fe26db6cc4d81d41a5a81ca0846fa680372a49.Full text
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 1 of
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Exhibit 38
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 2 of
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Document Provided in Native Format
RHMDL00047970
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 3 of
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Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
MARGIN REQUIREMENTS
Initial margin requirement set to 50% and maintenance margin GME Fractional - Applicable 2021-01-25 4:05:52 2021-01-25 8:04:50 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 25% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 56% and maintenance margin GME Fractional - Applicable 2021-01-25 8:04:50 2021-01-25 8:05:24 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 45% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 50%. GME Fractional - Applicable 2021-01-25 8:05:24 2021-01-26 4:54:03 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 68% and maintenance margin EXPR Fractional - Applicable 2021-01-26 4:07:36 2021-01-26 5:05:48 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 60% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 68% and maintenance margin TR Fractional - Applicable 2021-01-26 4:07:46 2021-01-28 8:56:41 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 60% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 68% and maintenance margin GME Fractional - Applicable 2021-01-26 4:54:03 2021-01-26 4:54:39 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 60% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 84% and maintenance margin GME Fractional - Applicable 2021-01-26 4:54:39 2021-01-26 5:05:01 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 80% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 80% GME Fractional - Applicable 2021-01-26 5:05:01 2021-01-27 5:06:54 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% EXPR Fractional - Applicable 2021-01-26 5:05:48 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% GME Fractional - Applicable 2021-01-27 5:06:54 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% DDS Fractional - Applicable 2021-01-28 8:13:43 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% LGND Fractional - Applicable 2021-01-28 8:14:05 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% BBBY Fractional - Applicable 2021-01-28 8:15:00 2021-01-29 9:03:35 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% FIZZ Fractional - Applicable 2021-01-28 8:15:24 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% AMCX Fractional - Applicable 2021-01-28 8:18:17 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% MAC Fractional - Applicable 2021-01-28 8:19:30 2021-04-14 4:11:20 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% SPWR Fractional - Applicable 2021-01-28 8:22:22 2021-02-09 6:41:58 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% SKT Fractional - Applicable 2021-01-28 8:23:00 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% AXDX Fractional - Applicable 2021-01-28 8:23:00 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 100% BB Fractional - Applicable 2021-01-28 8:28:27 2021-01-28 8:33:09 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 72% and maintenance margin BB Fractional - Applicable 2021-01-28 8:33:09 2021-01-29 9:02:25 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 65% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 4 of
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Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
Initial margin requirement set to 100% TR Fractional - Applicable 2021-01-28 8:56:41 2021-01-29 9:05:02 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 50% and maintenance margin NOK Fractional - Applicable 2021-01-29 6:40:15 2021-01-29 6:47:46 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 25% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 68% and maintenance margin TRVG Fractional - Applicable 2021-01-29 6:40:20 2021-01-29 6:47:51 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 60% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial margin requirement set to 60% and maintenance margin NOK Fractional - Applicable 2021-01-29 6:47:46 2021-01-29 7:15:55 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
requirement set to 50% Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% TRVG Fractional - Applicable 2021-01-29 6:47:51 2021-02-26 4:06:45 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% NOK Fractional - Applicable 2021-01-29 7:15:55 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% AAL Fractional - Applicable 2021-01-29 7:17:03 2021-05-25 8:54:48 Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% BB Fractional - Applicable 2021-01-29 9:02:25 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% BBBY Fractional - Applicable 2021-01-29 9:03:35 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
Initial and maintenance margin requirement set to 100% TR Fractional - Applicable 2021-01-29 9:05:02 Requirement Ongoing Jim Swartwout, President and RHS increased margin requirements for certain symbols for
Drip - Applicable Chief Operating Officer of RHS risk management purposes given extreme market volatility.
Recurring - Applicable
POSITION LIMITS (PRE-JANUARY 28, 2021 PCOS)
Option Contract Position Limits
Reduced position limits for options contracts from 5,000 to GME N/A 2021-01-26 16:52:21 2021-01-27 13:28:28 Jim Swartwout, President and RHS reduced position limits for options contracts for
3,000 Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Reduced position limits for options contracts from 5,000 to AMC N/A 2021-01-27 10:01:12 2021-01-27 15:47:44 Jim Swartwout, President and RHS reduced position limits for options contracts for
1,000 Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Reduced position limits for options contracts from 5,000 to EXPR N/A 2021-01-27 10:23:05 2021-01-28 20:58:09 Jim Swartwout, President and RHS reduced position limits for options contracts for
1,000 Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Reduced position limits for options contracts from 5,000 to TR N/A 2021-01-27 10:23:05 2021-01-28 20:58:09 Jim Swartwout, President and RHS reduced position limits for options contracts for
1,000 Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Reduced position limits for options contracts from 3,000 to 300 GME N/A 2021-01-27 13:28:28 2021-01-27 15:47:44 Jim Swartwout, President and RHS reduced position limits for options contracts for
Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Reduced position limits for options contracts from 300 to 100 GME N/A 2021-01-27 15:47:44 2021-01-28 20:58:09 Jim Swartwout, President and RHS reduced position limits for options contracts for
Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Reduced position limits for options contracts from from 1,000 AMC N/A 2021-01-27 15:47:44 2021-01-28 20:58:09 Jim Swartwout, President and RHS reduced position limits for options contracts for
to 100 Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Implemented PCO restrictions for options contracts expiring on AMC N/A 2021-01-27 20:56:24 2021-01-28 20:23:03 Jim Swartwout, President and RHS reduced position limits for options contracts for
January 29, 2021 Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 5 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
GME N/A 2021-01-27 20:21:37 2021-01-28 20:20:18 Jim Swartwout, President and RHS reduced position limits for options contracts for
Chief Operating Officer of RHS certain symbols for risk management purposes because
those symbols were subject to extreme market volatility.
Equity Position Limits
Imposed $10,000 equity position limits for all customer AMC Fractional - Not Applicable 2021-01-28 1:32:23 2021-01-28 21:08:36 Jim Swartwout, President and RHS imposed position limits on equities for certain
accounts for the following: Drip - Not Applicable Chief Operating Officer of RHS symbols for risk management purposes because those
Recurring - Not Applicable symbols were subject to extreme market volatility.
BB Fractional - Not Applicable 2021-01-28 1:32:23 2021-01-28 21:08:36 Jim Swartwout, President and RHS imposed position limits on equities for certain
Drip - Not Applicable Chief Operating Officer of RHS symbols for risk management purposes because those
Recurring - Not Applicable symbols were subject to extreme market volatility.
EXPR Fractional - Not Applicable 2021-01-28 1:32:23 2021-01-28 21:08:36 Jim Swartwout, President and RHS imposed position limits on equities for certain
Drip - Not Applicable Chief Operating Officer of RHS symbols for risk management purposes because those
Recurring - Not Applicable symbols were subject to extreme market volatility.
GME Fractional - Not Applicable 2021-01-28 1:32:23 2021-01-28 21:08:36 Jim Swartwout, President and RHS imposed position limits on equities for certain
Drip - Not Applicable Chief Operating Officer of RHS symbols for risk management purposes because those
Recurring - Not Applicable symbols were subject to extreme market volatility.
KOSS Fractional - Not Applicable 2021-01-28 1:32:23 2021-01-28 21:08:36 Jim Swartwout, President and RHS imposed position limits on equities for certain
Drip - Not Applicable Chief Operating Officer of RHS symbols for risk management purposes because those
Recurring - Not Applicable symbols were subject to extreme market volatility.
NOK Fractional - Not Applicable 2021-01-28 1:32:23 2021-01-28 21:08:36 Jim Swartwout, President and RHS imposed position limits on equities for certain
Drip - Not Applicable Chief Operating Officer of RHS symbols for risk management purposes because those
Recurring - Not Applicable symbols were subject to extreme market volatility.
PCO RESTRICTIONS
Equity PCO
Implemented temporary PCO restrictions for equity symbols AAL Fractional - Applicable 2021-01-28 10:06:23 2021-01-28 21:41:28 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
AMC Fractional - Applicable 2021-01-28 8:07:31 2021-01-28 21:41:40 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
BB Fractional - Applicable 2021-01-28 8:09:28 2021-01-28 21:41:42 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
BBBY Fractional - Applicable 2021-01-28 8:10:19 2021-01-28 21:41:27 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
CTRM (no option equivalent) Fractional - Applicable 2021-01-28 8:09:55 2021-01-28 21:41:36 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 6 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
EXPR Fractional - Applicable 2021-01-28 8:10:51 2021-01-28 21:41:35 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
GME Fractional - Applicable 2021-01-28 8:03:34 2021-01-28 21:41:41 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
KOSS (no option equivalent) Fractional - Applicable 2021-01-28 8:11:09 2021-01-28 21:41:34 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
NAKD (no option equivalent) Fractional - Applicable 2021-01-28 8:10:02 2021-01-28 21:41:43 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
NOK Fractional - Applicable 2021-01-28 8:08:24 2021-01-28 21:41:41 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
SNDL Fractional - Applicable 2021-01-28 9:53:24 2021-01-28 21:41:30 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
TR Fractional - Applicable 2021-01-28 9:54:04 2021-01-28 21:41:29 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
TRVG Fractional - Applicable 2021-01-28 8:09:23 2021-01-28 21:41:43 Jim Swartwout, President and RHS imposed temporary PCO restrictions on certain
Drip - Applicable Chief Operating Officer of RHS symbols to ensure that RHS would continue to meet
Recurring - Applicable National Securities Clearing Corporation’s (“NSCC”)
deposit requirements. These symbols were the largest
contributors to the NSCC “Value-at-Risk” or “VaR”
charge and were viewed as presenting significant risk based
on ongoing market conditions.
Option Contract PCO
Implemented temporary PCO restrictions for options contracts AAL N/A 2021-01-28 10:07:04 2021-01-28 20:28:28 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 7 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
AMC N/A 2021-01-28 8:36:01 2021-01-28 20:23:04 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
BB N/A 2021-01-28 8:34:17 2021-01-28 20:29:22 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
BBBY N/A 2021-01-28 8:35:16 2021-01-28 20:25:52 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
EXPR N/A 2021-01-28 8:34:44 2021-01-28 20:01:14 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
GME N/A 2021-01-28 8:35:55 2021-01-28 20:20:18 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
NOK N/A 2021-01-28 8:33:35 2021-01-28 20:03:28 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
SNDL N/A 2021-01-28 9:57:33 2021-01-28 20:18:08 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
TR N/A 2021-01-28 9:57:36 2021-01-28 19:54:36 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
TRVG N/A 2021-01-28 10:09:33 2021-01-28 20:00:18 Jim Swartwout, President and RHS imposed temporary PCO restrictions on options
Chief Operating Officer of RHS contracts for these symbols to ensure consistency of
limitations, so that restrictions would apply to all
transactions in these symbols, whether in equities or
options contracts.
Restricted trading on options contracts expiring on January 29, GME (Options contracts with strike price of 310 N/A 2021-01-27 21:01:00 Restriction expired at close Jim Swartwout, President and RHS restricted trading in GME options contracts expiring
2021 and 320) of day on January 29. Chief Operating Officer of RHS on January 29, 2021 to reduce customer risk associated
with early sellouts of expiring options contracts.”
GME (Options contracts with strike price N/A 2021-01-28 22:06:00 Restriction expired at close Jim Swartwout, President and RHS restricted trading in GME options contracts expiring
between 580 and 650) of day on January 29. Chief Operating Officer of RHS on January 29, 2021 to reduce customer risk associated
with early sellouts of expiring options contracts.”
Implemented PCO restrictions for options contracts expiring on AAL N/A 2021-01-28 20:28:55 Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
January 29, 2021 of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
AMC N/A 2021-01-28 20:23:35 Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
BB N/A 2021-01-28 20:29:53 Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 8 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
BBBY N/A 2021-01-28 20:26:00 Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
GME N/A 2021-01-28 21:40:00 Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
NOK N/A 2021-01-28 20:04:00 - Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
20:14:26* of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
*Time range to implement
PCO restrictions across all
expiring NOK option
series.
SNDL N/A 2021-01-28 20:22:20 Restriction expired at close Jim Swartwout, President and RHS imposed PCO restrictions on options contracts
of day on January 29. Chief Operating Officer of RHS expiring on January 29, 2021 to reduce customer risk
associated with early sellouts of expiring options contracts.
Fractional Trading PCO
Implemented PCO restrictions on fractional trading AAL Drip - Applicable 2021-01-28 22:28:50 2021-01-30 22:37:01 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
AMC Drip - Applicable 2021-01-28 22:29:20 2021-02-03 7:53:42 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
BB Drip - Applicable 2021-01-28 22:29:41 2021-02-02 10:49:44 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
BBBY Drip - Applicable 2021-01-28 22:30:01 2021-01-30 22:27:34 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
CTRM Drip - Applicable 2021-01-28 22:30:22 2021-01-30 22:30:18 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
CTRM Drip - Applicable 2021-02-01 4:32:32 2021-02-10 4:28:50 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
EXPR Drip - Applicable 2021-01-28 22:31:02 2021-02-02 20:14:55 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
GME Drip - Applicable 2021-01-28 22:32:21 2021-02-03 4:30:21 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
KOSS Drip - Applicable 2021-01-28 22:32:39 2021-02-02 10:49:46 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
NAKD Drip - Applicable 2021-01-28 22:33:02 2021-02-02 20:14:31 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
NOK Drip - Applicable 2021-01-28 22:33:24 2021-02-02 20:15:30 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 9 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
SNDL Drip - Applicable 2021-01-28 22:33:46 2021-01-30 22:32:02 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
TR Drip - Applicable 2021-01-28 22:34:18 2021-01-30 22:36:10 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
TRVG Drip - Applicable 2021-01-28 22:34:38 2021-01-30 22:36:39 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Recurring - Applicable Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
Implemented PCO restrictions on fractional trading ACB N/A 2021-01-29 15:10:15 2021-01-30 22:20:38 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
AG N/A 2021-01-29 15:10:37 2021-01-30 22:21:52 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
AMD N/A 2021-01-29 15:11:07 2021-01-30 22:23:54 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
BYND N/A 2021-01-29 15:11:50 2021-01-30 22:27:38 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
CCIV N/A 2021-01-29 15:12:11 2021-01-30 22:28:33 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
CLOV N/A 2021-01-29 15:12:38 2021-01-30 22:29:01 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
CRIS N/A 2021-01-29 15:13:00 2021-01-30 22:29:44 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
EZGO N/A 2021-01-29 15:13:42 2021-01-30 22:31:07 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
GM N/A 2021-01-29 15:14:30 2021-01-30 22:37:29 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
HIMS N/A 2021-01-29 15:15:13 2021-01-30 22:33:35 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
INO N/A 2021-01-29 15:29:53 2021-01-30 22:33:54 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
IPOE N/A 2021-01-29 15:30:26 2021-01-30 22:34:17 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
IPOF N/A 2021-01-29 15:30:46 2021-01-30 22:34:37 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 10 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
JAGX N/A 2021-01-29 15:31:04 2021-01-30 22:35:49 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
LLIT N/A 2021-01-29 15:31:35 2021-01-30 22:36:20 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
MRNA N/A 2021-01-29 15:31:53 2021-01-30 22:24:50 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
MUX N/A 2021-01-29 15:32:12 2021-01-30 22:29:04 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
NCTY N/A 2021-01-29 15:32:33 2021-01-30 22:29:38 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
NVAX N/A 2021-01-29 15:30:33 2021-01-30 22:26:59 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
OPEN N/A 2021-01-29 15:29:29 2021-01-30 22:21:33 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
RKT N/A 2021-01-29 15:29:01 2021-01-30 22:26:04 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
RLX N/A 2021-01-29 15:28:46 2021-01-30 22:18:34 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
SBUX N/A 2021-01-29 15:28:08 2021-01-30 22:23:25 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
SHLS N/A 2021-01-29 15:27:43 2021-01-30 22:22:56 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
SLV N/A 2021-01-29 15:27:03 2021-01-30 22:30:55 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
SOXL N/A 2021-01-29 15:26:20 2021-01-30 22:33:04 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
SRNE N/A 2021-01-29 15:25:35 2021-01-30 22:33:43 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
STPK N/A 2021-01-29 15:24:38 2021-01-30 22:34:28 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
TGC N/A 2021-01-29 15:23:32 2021-01-30 22:35:03 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 11 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
TIRX N/A 2021-01-29 15:23:04 2021-01-30 22:35:31 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
WKHS N/A 2021-01-29 15:21:09 2021-01-30 22:19:16 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
XM N/A 2021-01-29 15:20:27 2021-01-30 22:37:09 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
ZOM N/A 2021-01-29 15:18:44 2021-01-30 22:15:32 Jim Swartwout, President and RHS imposed PCO restrictions on fractional trading in
Chief Operating Officer of RHS certain symbols to ensure position limits placed on those
symbols would not be circumvented by fractional
purchases.
POSITION LIMITS (POST-JANUARY 28, 2021 PCOs)
Equity Position Limits
Imposed limits on purchase of equity shares AAL (55) Fractional - Not Applicable 2021-01-28 21:08:36 2021-01-29 12:02:20 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
AMC (115) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
BB (65) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
BBBY (30) requirements. RHS imposed the narrowest possible
CTRM (1650) quantity limits based on how RHS anticipated trading in
EXPR (200) these securities would affect NSCC’s VaR charge and
GME (5) adjusted the limits based on net trading activity.
KOSS (25)
NAKD (750)
NOK (110)
SNDL (1200)
TR (25)
TRVG (400)
Imposed limits on purchase of equity shares AAL (55) Fractional - Not Applicable 2021-01-29 12:02:20 2021-01-29 13:36:53 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
AMC (25) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
BB (25) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
BBBY (30) requirements. RHS imposed the narrowest possible
CTRM (1650) quantity limits based on how RHS anticipated trading in
EXPR (200) these securities would affect NSCC’s VaR charge and
GME (2) adjusted the limits based on net trading activity.
KOSS (10)
NAKD (300)
NOK (50)
SNDL (1200
TR (25)
TRVG (400)
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 12 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
Imposed limits on purchase of equity shares AAL (5) Fractional - Not Applicable 2021-01-29 13:36:53 2021-01-29 14:48:07 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
AG (5) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
AMC (10) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
AMD (1) requirements. RHS imposed the narrowest possible
BB (5) quantity limits based on how RHS anticipated trading in
BBBY (2) these securities would affect NSCC’s VaR charge and
CTRM (100) adjusted the limits based on net trading activity.
EXPR (5)
GME (1)
GTE (150)
JAGX (30)
KOSS (1)
MRNA (1)
NAKD (50)
NCTY (5)
NOK (20)
RYCEY (75)
SLV (5)
WKHS (3)
XM (2)
Imposed limits on purchase of equity shares for the following: 49 symbols: GME (1); AMC (1); NAKD (5); Fractional - Not Applicable 2021-01-29 14:48:07 2021-01-29 15:24:27 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (1); NOK (5); KOSS (1); EXPR (5); CTRM Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
1. AAL (5); BBBY (1) XM (1); MRNA (1); NCTY (1); Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
2. ACB GTE (5); RYCEY (5); AAL (1); AG (1); SLV requirements. RHS imposed the narrowest possible
3. AG (1); WKHS (1); AMD (1); JAGX (5); NVAX quantity limits based on how RHS anticipated trading in
4. AMC (1); SHLS (1); TGC (5); SRNE (1); IPOE (1); these securities would affect NSCC’s VaR charge and
5. AMD SOXL (1); SBUX (1); IPOF (1); ZOM (5); LLIT adjusted the limits based on net trading activity.
6. BB (5); CCIV (1); MUX (5); BYND (1); HIMS (1);
7. BBBY EZGO (5); INO (1); CLOV (1); CRIS (1); TIRX
8. BYDDY (1); TRVG (5); GM (1); TRXC (5); RKT (1);
9. BYND STPK (1); OPEN (1); ACB (1); RLX (1); SIEB
10. CCIV (5); BYDDL (1)
11. CLOV 51 symbols: GME (1); AMC (1); NAKD (5); Fractional - Not Applicable 2021-01-29 15:24:27 2021-01-30 21:46:59 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
12. CRIS BB (1); NOK (5); KOSS (1); EXPR (5); CTRM Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
13. CTRM (5); BBBY (1) XM (1); MRNA (1); NCTY (1); Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
14. EXPR GTE (5); RYCEY (5); AAL (1); AG (1); SLV requirements. RHS imposed the narrowest possible
15. EZGO (1); WKHS (1); AMD (1); JAGX (5); NVAX quantity limits based on how RHS anticipated trading in
16. GM (1); SHLS (1); TGC (5); SRNE (1); IPOE (1); these securities would affect NSCC’s VaR charge and
17. GME SOXL (1); SBUX (1); IPOF (1); ZOM (5); LLIT adjusted the limits based on net trading activity.
18. GTE (5); CCIV (1); MUX (5); BYND (1); HIMS (1);
19. HIMS EZGO (5); INO (1); CLOV (1); CRIS (1); TIRX
20. INO (1); TRVG (5); GM (1); TRXC (5); RKT (1);
21. IPOE STPK (1); OPEN (1); ACB (1); RLX (1); SIEB
22. IPOF (5); BYDDL (1); SNDL (5); TR (1)
Imposed limits on purchases of equity shares AMC (10) Fractional - Not Applicable 2021-01-30 21:46:59 2021-02-01 11:08:16 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (700) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
EXPR (20) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
GME (1) requirements. RHS imposed the narrowest possible
GNUS (600) quantity limits based on how RHS anticipated trading in
KOSS (2) these securities would affect NSCC’s VaR charge and
NAKD (600) adjusted the limits based on net trading activity.
NOK (200)
AMC (75) Fractional - Not Applicable 2021-02-01 11:08:16 2021-02-01 13:22:05 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (700) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
EXPR (200) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
GME (4) requirements. RHS imposed the narrowest possible
GNUS (5000) quantity limits based on how RHS anticipated trading in
KOSS (25) these securities would affect NSCC’s VaR charge and
NAKD (6500) adjusted the limits based on net trading activity.
NOK (2000)
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 13 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
AMC (350) Fractional - Not Applicable 2021-02-01 13:22:05 2021-02-02 10:44:45 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (700) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
EXPR (1000) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
GME (20) requirements. RHS imposed the narrowest possible
GNUS (5000) quantity limits based on how RHS anticipated trading in
KOSS (150) these securities would affect NSCC’s VaR charge and
NAKD (6500) adjusted the limits based on net trading activity.
NOK (2000)
AMC (1250) Fractional - Not Applicable 2021-02-02 10:44:45 2021-02-02 20:15:27 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
EXPR (3000) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
GME (100) Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
NAKD (12000) requirements. RHS imposed the narrowest possible
NOK (2000) quantity limits based on how RHS anticipated trading in
these securities would affect NSCC’s VaR charge and
adjusted the limits based on net trading activity.
AMC (1250) Fractional - Not Applicable 2021-02-02 20:15:27 2021-02-03 20:59:12 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
GME (100) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
requirements. RHS imposed the narrowest possible
quantity limits based on how RHS anticipated trading in
these securities would affect NSCC’s VaR charge and
adjusted the limits based on net trading activity.
AMC (5500) Fractional - Not Applicable 2021-02-03 20:59:12 2021-02-04 21:17:50 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
GME (500) Drip - Not Applicable Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
Recurring - Applicable to ensure RHS would continue to meet NSCC’s deposit
requirements. RHS imposed the narrowest possible
quantity limits based on how RHS anticipated trading in
these securities would affect NSCC’s VaR charge and
adjusted the limits based on net trading activity.
Option Contract Position Limits
Imposed limits on purchases of options contracts AAL (50) N/A 2021-01-28 20:58:09 2021-01-28 21:14:41 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
AMC (100) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
BBBY (50) to ensure RHS would continue to meet NSCC’s deposit
DASH (1000) requirements. RHS imposed the narrowest possible
DDS (1000) quantity limits based on how RHS anticipated trading in
EXPR (100) these securities would affect NSCC’s VaR charge and
FIZZ (1000) adjusted the limits based on net trading activity.
FOSL (1000)
GME (10)
GSX (1000)
IRBT (1000)
M (1000)
NOK (100)
SKT (1000)
SNDL (100)
SPCE (1000)
TR (50)
TRVG (100)
*NAKD and KOSS inadvertently added and
removed on 2021-01-28 21:14:41
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 14 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
Imposed limits on purchases of options contracts AAL (25) N/A 2021-01-28 21:14:41 2021-01-29 13:42:13 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
AMC (50) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
BB (50) to ensure RHS would continue to meet NSCC’s deposit
BBBY (25) requirements. RHS imposed the narrowest possible
DASH (1000) quantity limits based on how RHS anticipated trading in
DDS (1000) these securities would affect NSCC’s VaR charge and
EXPR (50) adjusted the limits based on net trading activity.
FIZZ (1000)
FOSL (1000)
GME (5)
GSX (1000)
IRBT (1000)
M (1000)
NOK (50)
SKT (1000)
SNDL (50)
SPCE (1000)
TR (25)
TRVG (50)
Imposed limits on purchases of options contracts AAL (10) N/A 2021-01-29 13:42:13 2021-01-30 21:16:02 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
AMC (10) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
BB (10) to ensure RHS would continue to meet NSCC’s deposit
BBBY (10) requirements. RHS imposed the narrowest possible
DASH (1000) quantity limits based on how RHS anticipated trading in
DDS (1000) these securities would affect NSCC’s VaR charge and
EXPR (10) adjusted the limits based on net trading activity.
FIZZ (1000)
FOSL (1000)
GME (5)
GSX (1000)
IRBT (1000)
M (1000)
NOK (10)
SKT (1000)
SNDL (10)
SPCE (1000)
TR (10)
TRVG (10)
Imposed limits on purchases of options contracts AMC (10) N/A 2021-01-30 21:16:02 2021-02-01 11:12:11 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (700) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
DASH (1000) to ensure RHS would continue to meet NSCC’s deposit
DDS (1000) requirements. RHS imposed the narrowest possible
EXPR (20) quantity limits based on how RHS anticipated trading in
FIZZ (1000) these securities would affect NSCC’s VaR charge and
FOSL (1000) adjusted the limits based on net trading activity.
GME (5)
GSX (1000)
IRBT (1000)
M (1000)
NOK (1000)
SKT (1000)
SPCE (1000)
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 15 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
Imposed limits on purchases of options contracts AMC (75) N/A 2021-02-01 11:12:11 2021-02-01 13:25:33 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (700) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
DASH (1000) to ensure RHS would continue to meet NSCC’s deposit
DDS (1000) requirements. RHS imposed the narrowest possible
EXPR (200) quantity limits based on how RHS anticipated trading in
FIZZ (1000) these securities would affect NSCC’s VaR charge and
FOSL (1000) adjusted the limits based on net trading activity.
GME (5)
GSX (1000)
IRBT (1000)
M (1000)
NOK (1000)
SKT (1000)
SPCE (1000)
Imposed limits on purchases of options contracts AMC (350) N/A 2021-02-01 13:25:33 2021-02-02 10:45:07 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
BB (700) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
DASH (1000) to ensure RHS would continue to meet NSCC’s deposit
DDS (1000) requirements. RHS imposed the narrowest possible
EXPR (1000) quantity limits based on how RHS anticipated trading in
FIZZ (1000) these securities would affect NSCC’s VaR charge and
FOSL (1000) adjusted the limits based on net trading activity.
GME (20)
GSX (1000)
IRBT (1000)
M (1000)
NOK (1000)
SKT (1000)
SPCE (1000)
Imposed limits on purchases of options contracts AMC (1250) N/A 2021-02-02 10:45:07 2021-02-02 20:17:21 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
DASH (1000) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
DDS (1000) to ensure RHS would continue to meet NSCC’s deposit
EXPR (3000) requirements. RHS imposed the narrowest possible
FIZZ (1000) quantity limits based on how RHS anticipated trading in
FOSL (1000) these securities would affect NSCC’s VaR charge and
GME (100) adjusted the limits based on net trading activity.
GSX (1000)
IRBT (1000)
M (1000)
NOK (2000)
SKT (1000)
SPCE (1000)
Imposed limits on purchases of options contracts AMC (1250) N/A 2021-02-02 20:17:21 2021-02-03 20:57:14 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
DASH (1000) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
DDS (1000) to ensure RHS would continue to meet NSCC’s deposit
FIZZ (1000) requirements. RHS imposed the narrowest possible
FOSL (1000) quantity limits based on how RHS anticipated trading in
GME (100) these securities would affect NSCC’s VaR charge and
GSX (1000) adjusted the limits based on net trading activity.
IRBT (1000)
M (1000)
SKT (1000)
SPCE (1000)
Imposed limits on purchases of options contracts AMC (5000) N/A 2021-02-03 20:57:14 2021-02-04 21:16:55 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
DASH (1000) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
DDS (1000) to ensure RHS would continue to meet NSCC’s deposit
FIZZ (1000) requirements. RHS imposed the narrowest possible
FOSL (1000) quantity limits based on how RHS anticipated trading in
GME (500) these securities would affect NSCC’s VaR charge and
GSX (1000) adjusted the limits based on net trading activity.
IRBT (1000)
M (1000)
SKT (1000)
SPCE (1000)
Case 1:21-md-02989-CMA Document 567-38 Entered on FLSD Docket 06/07/2023 Page 16 of
16
Application to
Date and Timestamp Date and Timestamp
Fractional/Dividend
Trade Limit or Restriction Symbol (Equity/Option) — When Effective — When Removed Approver Reason
Reinvestment/Recurring
(Eastern) (Eastern)
Orders
Imposed limits on purchases of options contracts DASH (1000) N/A 2021-02-04 21:16:55 2021-02-18 12:06:28 Jim Swartwout, President and RHS imposed limits on certain symbols' options and
DDS (1000) Chief Operating Officer of RHS equities from January 29, 2021 through February 4, 2021
FIZZ (1000) to ensure RHS would continue to meet NSCC’s deposit
FOSL (1000) requirements. RHS imposed the narrowest possible
GSX (1000) quantity limits based on how RHS anticipated trading in
IRBT (1000) these securities would affect NSCC’s VaR charge and
M (1000) adjusted the limits based on net trading activity.
SKT (1000)
SPCE (1000)
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