92
Monopar Therapeutics Inc. (MNPR) from 8:12 a.m. EST on January 28, 2021 until 12:16 p.m.
EST on February 3, 2021; and GME from 9:29 a.m. EST on January 25, 2021 until 8:20 a.m. EST
on January 26, 2021 and again from 8:51 a.m. EST until 12:16 p.m. EST on February 3, 2021.
477
Interactive Brokers also placed several symbols into PCO for approximately nine hours.
478
With exceptions, these PCO restrictions were introduced by Interactive Brokers at 10:50 a.m. EST
on January 28, 2021, and were removed by 8:23 p.m. EST the same day.
479
Interactive Brokers explained to Committee staff that the company’s PCO restrictions on
January 28, 2021 were motivated by general risk management concerns rather than liquidity or
capitalization concerns.
480
On January 28, 2021, Interactive Brokers’ daily NSCC collateral
deposit requirement was approximately $1.3 billion, and the firm had reported excess capital of
approximately $4.4 billion.
481
Interactive Brokers stated that it restricted trading “to protect the
firm and its customers from incurring outsized losses due to wild swings in price in a volatile and
unstable marketplace.”
482
Interactive Brokers expressed concern about the effect of the high
volatility on the clearinghouses, broker-dealers, and market participants.
483
477
Id. Short sale restrictions at Interactive Brokers generally did not apply to execution only customers, who are
customers that only execute orders through Interactive Brokers but do not clear and settle their trades through the firm.
Interactive Brokers’ execution only customers are generally either buy-side institutions, such as mutual funds, hedge
funds and other investment vehicles that rely on a broker-dealers other than Interactive Brokers as their prime broker-
dealer or custodian or, alternatively, other broker-dealers (whether US or foreign) that submit orders for their own
account or for their customers (whether they are retail or non-retail).
478
Appendix A to Letter from Chief Counsel of Investigations and Enforcement at Interactive Brokers, to Chairwoman
Waters and Chairman Green (Feb. 19, 2021). The symbols subject to position closing only limitations were: Fossil
Group Inc. (FOSL), BlackBerry Ltd. (BB), Nokia Corp. (NOK), Nokia Oyj (NOKN), Nokia Oyj (NOAA), Nokia
(NOKIASEK), Nokia (NOKIA), Express, Inc. (EXPR), Express, Inc. (02Z), Koss Corp. (KOSS), AMC Entertainment
Holdings Inc. (AMC), Bed Bath & Beyond Inc. (BBBY), Bed Bath & Beyond Inc. (BBY), GameStop (GME),
GameStop Corp. (GS2C), AeroCentury Corp. (ACY), Janone Inc. (JAN), Janone Inc. (5AR1), Monopar Therapeutics
Inc. (MNPR), New Concept Energy, Inc. (GBR), Lianluo Smart Ltd. (LLIT), and Lianluo Smart Ltd. (J8D1).
479
Appendix A to Letter from Chief Counsel of Investigations and Enforcement at Interactive Brokers, to Chairwoman
Waters and Chairman Green (Feb. 19, 2021). The position closing only restrictions on certain symbols were introduced
and lifted at different times on January 28, 2021. Specifically, for Bed Bath & Beyond, Inc. (BBY) and 02Z, the
restriction was introduced at 1:51 p.m. EST and lifted at 8:23 p.m. EST; for GameStop (GME) and Koss Corp.
(KOSS), the restriction was introduced at 7:56 a.m. EST and lifted at 8:23 p.m. EST; for GS2C, the restriction was
introduced at 11:46 a.m. EST and lifted at 8:23 p.m. EST; for ACY, JAN and MNPR, the restriction was introduced
at 7:56 a.m. EST and lifted at 9:00 p.m. EST; for 5AR1, the restriction was introduced at 13:51 p.m. EST and lifted at
9:42 p.m. EST; for GBR, the restriction was introduced at 12:32 p.m. EST and lifted at 9:42 p.m. EST; for LLI, the
restriction was introduced at 11:41 a.m. EST and lifted at 9:42 p.m. EST; and for J8D1, the restriction was introduced
at 1:51 p.m. EST and lifted at 9:42 p.m. EST. In some instances, these restrictions took thirty minutes or more to be
applied across the Interactive Brokers platform from the time that risk personnel introduced them.
480
Interactive Brokers briefing with the Committee (Jun. 14, 2021).
481
Id. The approximately $4.4 billion excess net capital figure is based on data from the firm’s Financial and
Operational Combined Uniform Single Report (FINRA FOCUS Report) filed on January 27, 2021, and which would
have been referred to by the NSCC on January 28, 2021. Interactive Brokers’ FINRA FOCUS Report for the period
ending January 31, 2021 reflected excess net capital of approximately $3.8 billion.
482
Interactive Brokers, FAQs: Securities subject to Special Requirements, Interactive Brokers (last accessed Sept. 17,
2021).
483
Id.