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» Elkins/McSherry, LLC
Recent market conditions have raised concerns that short selling in the securities of a wide range of financial institutions may be causing sudden and excessive fluctuations of the prices of such securities in such a manner to threaten fair and orderly markets.
Pursuant to Section 12(k)(2) of the Securities Exchange Act of 1934, on September 18, 2008, the Securities and Exchange Commission issued an Emergency Order related to short selling the publicly traded securities of certain financial firms. The Order was effective immediately.
Pursuant to this Order: Vandham Securities Corp. may not knowingly effect a short sale as part of bona fide market making and hedging activity related directly to bona fide market making in a derivative security based on a Covered Security, "if" the customer's or counterparty's transaction will result in the counterparty establishing or increasing an economic net short position (i.e. through actual positions, derivatives, or otherwise) in the issued share capital of a firm covered by the Order.
The entire Order and guidance can be accessed at www.sec.gov.
Any questions can be addressed to Eugene Torpey Director of Compliance at Eugene.firstname.lastname@example.org