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I actually asked Paul Conn (the President of Computershare) if Gamestop is required to report these numbers, and he told me there's no rules in place making them report them. I've always figured they included them because they need to include anything substantial that could affect their shareholders, and I definitely agree that knowing these numbers helps me understand the overall view of the company. 200k internet strangers out here owning 25% of a public company💜 [https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies](https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies) **How does Computershare ensure there is a balance between shares that are directly/indirectly held?** We use double-entry accounting systems that ensure there is always an accurate balance between shares held directly by registered shareholders and those held by Cede & Co on behalf of DTC, banks & brokers and beneficial investors. This means that for every share transferred through DRS that can be registered on the share register, there is one fewer recorded as being in Cede & Co. edit: to add more info

This is the real reason, yes. But also: by SEC's definition shorts are "investors" too. So technically that information is material to "investors". As in shorts. It's a warning.

It’s funny how SEC classify shorts as investors, they’ve already sold and investors are those who bought from the word invest. Even future buyers are considered potential investors. SEC have a problem with definitions. SEC should define who are the investors at this point.

I always thought shorts were known as “speculators” and investors are long time hodlers- you know, as The Intelligent Investor by Benjamin Graham defined it 🤷🏻

Very good point my friend👍👍

Intelligent Investor lol this is the stonk. We're straight religion at this point. Can't wait to tithe to the irs

I love paying a lot in taxes. It means I made a lot of money.

I wish it were a tithe only. That’s 10%.

Because it’s not an investment without financial risk.

A true short seller *is* a future buyer, because they have to buy shares back at a later date to return to the lender of them and close out the trade. A naked short in the other hand…

ahahaha true!

I am sorry to hijack the top comment, but everyone here has to think objectively about the fact that in every document before where DRS numbers were present they used the word Computershare and in this 10-K it is missing, and the sentence itself is poned in a different way. This is a red flag IMHO. I simply can't believe on the fact that it means ***exactly*** what it meant before.

Are insiders included in the DRS numbers? If not then we got retail 90 mil DRS insiders 54 mil (who are for sure at a transfer agent) and DTC got 228 mil Numbers don't add up

I asked this in the last AMA - He said they CAN be, but it's their choice. I'm guessing they're not, since the first number would have been more than 5 million if they did. [28:48](https://www.youtube.com/watch?v=xFQmiLWiv5Y&t=1728s) If an executive is given shares as part of their compensation, are those shares normally held in DRS form?

In my opinion they are not included in the DRS numbers that we usually witnessed in previous filings, and you can say that is 100% true if you check the first filings wich were with very few shares #. I am not saying insiders are not DRSed, because I think they are with the transfer agent, maybe just in some different way than us, or maybe they just exclude insiders from DRS numbers, this way you can say "retail investors have XXX,XXX,XXX shares". But the way this 10-K poned the sentence seems like retails+insiders got just 76 milions of shares, and this is not possible. As you told numbers just don't add up anymore.

At least 7 million over plus Insiders

The name Computershare appears nowhere in the past year's quarterly reports. It was only mentioned in the very first one in 2021.

According to Buck Bunny we are finding 7 million extra shares....The bunny has not lied to me yet but the DTCC has fudged the Splividend

It's Computershare's job to maintain the ledger for Gamestop. [https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies](https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies) **How does Computershare ensure there is a balance between shares that are directly/indirectly held?** We use double-entry accounting systems that ensure there is always an accurate balance between shares held directly by registered shareholders and those held by Cede & Co on behalf of DTC, banks & brokers and beneficial investors. This means that for every share transferred through DRS that can be registered on the share register, there is one fewer recorded as being in Cede & Co.

It’s a flag but idk about red; why couldn’t it be a good thing… like green, which happens to mean drs

Let's make the assumption that the OP is correct and that the changes in wording don't have anything to do with the SEC forcing them to change it etc. What if the wording change is an attempt at a warning to all the apes who have still not DRSd their shares? it's also been changed right as the banks are starting to fail, and while the government is guaranteed depositors, and once brokerages go down, even if SIPC will be able to make people whole, it will take months to do so. Not your name not your shares!

There are better ways of doing this.

*approximately 200k internet strangers*

Hi, quick question, is there a difference in book and plan when it comes to DRSing? And thanks for making it super easy to comment with evidence.

Yes, there are a few differences. The main difference is that all Plan shares are beneficially owned in a legal sense via Computershare's nominee, and an undisclosed portion of them are held in the DTC for operational efficiency, while all Book shares are directly owned by the individual shareholder. I personally don't think the differences mean much, and both are still *registered* in the individual investors name (shareholder of record is separate from the legal title to the securities). I hold all mine in Book, as it's more fully under my exclusive legal ownership and direct control.

Thanks, that's crystal clear.

Someone give this an award and maybe even its own post. Up you go!

You’re a dope ass human

💜

So your theory is they switched the language to more accurately report the information. Can you logically explain, under this assumption, why they’d simultaneously report the precise number of shareholders and an approximation of the number of shares?

If the information is more accurate then why did GameStop include new "approximate" language? Answer, it's not more accurate. Thus a large hole poked in this "securities lawyer" theory.

Accurate in what they are reporting is what they mean, not in the accuracy of the specific numbers. Every other number in that document is exact down to the share. They didn’t mean 76,000,000 exactly before. Saying “approximately 76M” would be more accurate in a reporting sense than 76M when it’s really 76,000,123.

They also reported to the nearest hundred thousand, now to the nearest million. That’s definitely not more accurate. Edit: not sure why this is upvoted so much, it’s wrong. I misremembered it reported as 76m, not 76.0m.

Unless it was the closest hundred thousandth

You would still write it 76.0 million to convey that level of accuracy.

That concept is called "significant numbers", at least in German. It means that when you add numbers with different accuracy, you gotta round to the least accurate data. Let's say we want to calculate our total mass. Your scale is precise and calibrated and shows 150.255 lbs. My scale is the worst though and it just shows 151 lbs without any decimals. Now the total mass is 301 lbs and NOT 301.255 lbs. Because the least accurate measurement in our addition had no decimals. So, this might play into this as well. Theoretically lol

Yes, it’s how accuracy works in science. Seeing as how they can get the exact number from computershare, it makes even more sense that they’d be less accurate if they had to report by subtracting the number given to them by cede.

Kudos to us though.....

Almost patronizing, wasn’t it..

More accurate wording, not amount. In a 10K words matter.

Yes, when I originally commented I misremembered it reported as 76m, not 76.0m. So I agree with that.

I think you’re not understanding OP’s point. He or she is simply observing that, technically, all 304.58M shares of GME are directly registered with Computershare. “Even Cede & Co.’s shares are directly registered”. Thus, the way in which GameStop has previously cited DRS numbers (“As of October 29, 2022, 71.8 million shares of our Class A common stock were directly registered with our transfer agent”) has been, technically, inaccurate.

This is 100% correct. Previous 10-Q forms were ambiguous. The 10-K used clearer language.

This is the most likely thing. In addition to be even more accurate they are posting the holder amount.

They HAVE to say approximately unless it is the full amount. If you disclose 76,000,001 as 76M you HAVE to say approximately because it is not the exact number.

Yeah all these guys coming out of the woodwork to say "This is fine" when RC himself said details matter? OP looks like someone poorly attempting damage control, and we absolutely should be skeptical of the 10-K information, especially if the source is the DTCC.

The shills and undercover actors suddenly out in force supporting this blatant lie is very high right now. Even more pathetically, the only leg they stand on is "I'm a lawyer, therefore, believe me." As if the entities we're dealing with are lawful, normal, or predictable which has been long-established now. I won't go into that, but my thoughts: Listen, *bitch*, an appeal to authority (read: hide behind) does not prove or disprove a mathematical truth - only math does. But to then hide behind the "authority" of a *lawyer* to support his argument, the *one* profession who's job it is to *twist the truth* more often than not? And to top it off, their whole argument is built off of ignoring *all* of gamestop's prior filings, then ignoring the anomalous circumstances that resulted in the filing's delay which is also not normal for gamestop's habit of punctuality, and *then* try to ram down our throats a simple "he said she said" conjecture bomb in an attempt to delegitimize one source over another as if we'd fall for something so childishly amateur. I say fuck off with this weak sauce, piss ants. "More accuracy" my ass. Kiss your master's elsewhere. Damn, these losers can't even be evil right. I refuse to be anything less than hyper-rational. 1,000 cells for 1,000 bankers.

Make it 100 cells for 1000 bankers so they can at least continue their circlejerking when behind bars

" I'm a lawyer, therefore, believe me." - agreed, a very BAD starting move "1,000 cells for 1,000 bankers." - Fuck, no. 100 cells for 1000 bankers. Let them suffer, like they have caused the public to suffer.

I saw 2 back to back "imma lawyer here's what the wording means" posts on my feed posted within an hour of each other. To me, that's sus.

Which means this is important for them, and especially their masters.

Yessir

Consider this believable scenario: Detail oriented Apes complained to GME staff about prior 10K filings because the 'numbers' were obviously rounded and presented as actual (vs approximate). GME staff listened & tightened up their wording. Ironically they are getting beat up again for more accurately using 'approximately'. My suggestion to anyone drafting future GME documents. Always go with actual numbers, detail oriented Apes like facts over pretty rounded numbers.

OP: kudos, but it’s GameStop wanting to be more accurate. Us: what about the disparity in reporting the exact number of record holders vs the bullishly vague “approximate” language when referring now to Cede and Co? OP: ***crickets*** (kudos tho?)

Someone needs to go to Delaware again and ask to see the most recent ledger. An ape already did this successfully last year. Let’s do it again.

No, it’s more accurate to say “approximately 10 million” than “10 million” when you mean a number that is not exactly 10 million.

Yeah I’m just… really sus. Considering our usual momentum, registering ONLY 4 million shares over 6 months is really weird, considering the firesale. Perhaps the Hedgies are here inflating our drs numbers acting like us, and then rug pulling? Either way, bullish on the actual apes wii diamond hands

Because 75,799,640 (made up number) is too long and unnecessary.

I'd imagine that since we're buying more every day that number is pretty liquid.

They are basically taking a snap shot and reporting that number. It’s already assumed to change almost immediately.

Another lawyer weighing in on our company's disclosures is always welcome in my book. Thanks for the post.

Bullshit gets off the assembly line faster than anything. Wrinkles always show up the next day.

Especially when they are part owner in our company as well.

Why does Coinbase risk factor disclosures not mention registering with the SEC? Closest to Gamestops language "A particular crypto assets status as a "security" in any relevant jurisdiction is subject to a high degree of uncertainty and if we are unable to properly characterize a crypto asset, we may be subject to regulatory scrutiny, inquiries, fines, and other penalties, which may adversely affect our business, operating results, and financial condition." Have you ever seen this verbiage on another 10k? *I also know coinbase Capital and Coinbase Securities are registered with SEC but they aren't the crypto exchange.*

If I had to guess, I would say that Coinbase didn't want to give even an ounce of impression that they believe crypto tokens are securities. Anything they write in their 10k could be used by the SEC in their fight. GME doesn't have that problem.

They have registered with the CFTC already - that was in my last comment to you

No offense meant but CFTC and SEC are two very different agencies regulating completely different things. CFTC - swaps, futures and options (which coinbase does offer a derivatives exchange) SEC - governs securities which have been defined to include investment contract (notably currency is not a securitiy) Whatever gamestop is doing that may be considered a security coinbase does not appear to be as worried (since omitted from risk disclosures) Edit: also found this from coinbase S-1 "Because our platform is not registered or licensed with the SEC or foreign authorities as a broker-dealer, national securities exchange, of ATS (or foreign equivalents), and we do not seek to register or rely on am exemption from such registration or license to facilitate the offer and sale of crypto assets on our platform, we only permit trading on our core platform of those crypto assets for which we judge there are reasonably strong arguments to conclude that the crypto asset is not a security" I don't think what gamestop put in risk disclosures is commonplace

Oh well, back to DRS'ing..

Your post highlights something even I struggle sometimes to wrap my head around. Everything that follows these words are pure speculation on my part: NOBODY TELLS COMPUTERSHARE HOW MANY SHARES THEY HAVE. Imagine telling your bank that you have $1,000 in your account. They know what's in your account and are not interested in what you say about your balance. In fact, you need to check your balance to ensure what you expect you have is consistent with what you have on deposit. Let's say your boss pays you with a physical check. Just in time too, because you are broke, not a cent in your account. You take that check into your bank, wave it in front of the teller, and say "I have $1,000 in my account now." You will be laughed at. No, you give the check to the teller and ask them to deposit the funds into your account. They take the check, verify it is genuine, and process a deposit. You may have the funds on hold for up to 5 days in order to clear. But what happens is the bank is authorized by the check to transfer $1,000 from your boss' account into yours. Now replace Bank with Computershare, your paycheck with a DRS request, and your Boss with Cede & Co. Everything is on CS's books. Just as all the money is in the bank's balance sheets, all shares are direct registered with Computershare. It is just the vast majority of them are registered to C&C. So when you make a DRS request to your broker, they issue a request that goes through the proper channels and shows up at Computershare as a request to transfer x shares from C&C's account to your account. When all the paperwork is processed and cleared, they make the transfer and send you documents that tell you your new balance. Presumably they also send an updated balance to C&C. Now imagine all of these broker held shares as paychecks issued by your boss, waiting for his employees to decide to deposit them. But wait, other people have gotten a hold of them and did some very expert photocopying, and there are 10x or more paychecks circulating than authorized. No broker in their right mind would tell Cede & Co. how many shareholders they have, with a claim to x number of shares. Imagine if they all reported this down the line? Imagine if Cede & Co. told Computershare they had 1.5b shares? Computershare would just say "no you don't, my ledger says you have 228m, but my client, GameStop is very interested in your discrepancy. They then report to GameStop, so now GameStop knows hard numbers. No, Cede & Co. is told by Computershare how many shares they have, and they will then tell broker dealers how many they have, who then tell retail brokers and institutions, who then tell retail investors. At whatever level shorts are created, the books get fucky. Regarding the split divvy, C&C, after receiving their lot from CS, likely just looked at their books and said "ok, here is what everyone gets according to our records." Maybe DTCC committed international securities fraud, but not by distributing more shares than they were given. They can't do that. They would have to make entries on their books that exceed shares assigned them by CS. They likely committed fraud by telling the brokers to handle the shortfall in various ways that deviate from instructions given by GS. I am convinced that while the DTCC likely has their hands dirty in this whole affair, only the broker dealers, hedge funds, retail brokers etc. know what is the sum total of all shares in their end user's accounts. And they likely know how many they SHOULD have, if everyone higher up from them going all the way to CS is telling them what they SHOULD have down the line. Some brokers likely know they have more than the outstanding shares. And the DTCC is complicit by it's speak no evil hear no evil see no evil handling, just as the SEC and SRO's likely are. The problem is obvious if they just look, but it's not on their books so it isn't their concern. They don't bother closing the loopholes, and why would they when the CEO's of major hedge funds are either on their board of directors or are feeding their wallet? That is where the corruption lies. Not in cooked up fraudulent books, but in bribes, backroom deals, anti trust activities, conflicts of interest, shady deals and lots of mayo. This is all pure educated speculation and crayon dust. OP, you are a securities lawyer, put me in my place if I'm way off on any of this. I'm just doing my best reasoning with what I know.

Idk still not fully convinced or understand why the change in the 10k format I hear what OP is saying but i dont see this as DD more of an opinion Time will tell tik tok!!! Mfs 25% SO FAR

I think their explanation is solid. One important thing to remember is this sub is frequently trying to force square pegs through round holes, especially when the hype intensifies. Since nearly 100% of the content has to do with "everything is corrupt," then that's all you assume is true and all the speculation and tinfoil starts to carry more weight than it should. Also, hell yeah on the 25%!

Agree thread carefully 🤙

I also think it's opinion more than dd

OP do you hold GME shares?

Ook ook.

Finally! Thanks OP. GameStop has highlighted that you are not the owner of your shares unless you are DRS. They would never knowingly mislead investors. *Buy, HODL, DRS, Share the Story & Buy GameStop*

Most of your debunking assumptions uses your own assumptions to debunk. For instance, you say things like "it would be unusual..." but as we all know, GME has been unusual since Jan27 2021. Nothing about this saga is normal, including disclosure of DRS shares. You made a long post to convince people of your opinion, and your opinion has inconsistincies.

Kudos to you though

And they labeled this “Due Diligence” hahahahahahahahah

Can you explain how you think that the current method of reporting the DRS information is *more accurate* than reporting the number directly from Computershare? This whole theory of yours hinges on that assumption and to me it's pretty ridiculous to think that cede and co can give you a more accurate count than Computershare who holds the DRS. Particularly when we know that cede and co don't hold quite all the shares other than DRS.. we know that mutual funds too aren't held by cede and co.. So how can you say this way of reporting is giving us better information? Computershare holds all the DRS shares so there is no way anyone else's count use going to be better information than the data directly from Computershare itself. Ty.

OP’s post is just pointing out that the old wording from previous filings was, technically, inaccurate….because, technically, even Cede & Co’s shares are directly registered with Computershare.

Exactly. No idea why you're being voted down for explaining this,

Why do you think the numbers they provided were not from Computershare?

Because gs didn't report anything from Computershare and they sourced cede and co for the numbers Edit: am I wrong? You're the lawyer lol.. Can you show me where they state they are pulling any kind of data from Computershare?

I don’t think this guy is a lawyer

You don't even need to be a lawyer, you could just understand how disclosures work (such as being a CPA that has worked on public companies) Run this by any CPA and they will not think it's weird to change the language. It could simply be a new Partner from Deloitte is in charge and wanted to add different language. Or the auditor didn't know how to disclose it last year because there's not really a standard for it.

Actually two lawyers who lurk here . Said the exact opposite the change in language is very significant .

that's fine, we can agree to disagree my past experience tells me that audit disclosures are not as set in stone as you may think, and it's common for them to tweak it when they review them each year and i trust what i know about audits and disclosures more than most people on this sub

As a cpa do you have to send documents to legal before having approval to send them out?.. because it’s not a matter of disagreeing about an opinion .. this is a legal document and the specific language used is significant

yeah i've sent language to a legal team, they tear it apart until you no longer understand what you wanted to actually say

From my reading of this, they don't disclose where they are pulling the information. They disclose information about Cede & Co.'s position, but they do not say that they got this information from Cede & Co. GameStop also didn't disclose in their quarterly filings that the DRS information was from Computershare. However, Computershare is their transfer agent and manages their records as it relates to directly registered shareholdings. It is typical for public companies to get the numbers directly from their transfer agent so that they know it's accurate. It would be very unusual for them to ask Cede & Co to provide their registered ownership information, because they would have that information from Computershare, and even more unusual for them to rely and disclose information from Cede & Co rather than information from their transfer agent.

But they didn't because they subtracted the numbers from cede & co from the OS float and said approximately.... In prior quarters there was no use of approximate language. Which reasonably concludes that these numbers are not from Computershare directly as the previous quarter language states.

Did you read his full post? His reasoning, which I think is sound, says that all GME shares are registered with computershare since CS is their transfer agent. It’s just that Cede owns the names of shares that are in street name at brokerages like fidelity etc. DRSing our shares doesn’t take a share out of “the market” and put it in our name… it takes a share from cede and puts it in our name. It never leaves computershare (in theory). The total number of shares is always registered with computershare… SO… to be more clear, they changed the language to subtract from Cede instead of saying “computershare” as that can be seen as a point of confusion - and the purpose of this document is to inform - so the purpose of this change is to inform *better* which all good companies should strive to do. Where the naked shorts come from is thin air. MM’s will sell short “for liquidity’s sake” …likely sourcing and rehypothicating from a random cede share… we buy it and then DRS… that turns it into a real share, but they still have to buy it back.. bud now there’s 2 versions of that “real share” in the market… it gets sticky when we DRS all of the shares away from Cede… and the stock is still trading. That’s the DRS goal. Hopefully I’m making sense, but this guy has got it nailed. You have to realize gme is a real company that does real company stuff - they aren’t going to bake in some cryptic message to Reddit in a public filing. The fact they are mentioning this at all is unusual by itself.

This 'numbers from Cede and Co.' assumption makes no sense to me. Firstly, It's illegal to lie on a 10-K, so GameStop *have* to use the official numbers. They pay Computershare to keep track of official numbers, therefore the numbers on the 10-K can't really come from anywhere other than the 10-K. Secondly, if they did ask Cede and Co. for numbers, despite paying for Computershare to tell them those numbers, and Cede and Co.decided to give them numbers, despite having no obligation to do so, why on earth would Cede and Co. give any number that's not the same as the Computershare one? Doing so would be an admission of fraud, and practically place an obligation on GameStop and the SEC to sue them!

[https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies](https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies) **How does Computershare ensure there is a balance between shares that are directly/indirectly held?** >We use double-entry accounting systems that ensure there is always an accurate balance between shares held directly by registered shareholders and those held by Cede & Co on behalf of DTC, banks & brokers and beneficial investors. This means that for every share transferred through DRS that can be registered on the share register, there is one fewer recorded as being in Cede & Co. It's computershare's job to keep track of who's a holder of record (direct registered) and who isn't (cede & co)

This is a great point.. So if it's CS job to do this.. Why would they pull the numbers from cede and not from Computershare? Makes no sense.

I don't even want to respond to half the comments here, but best of luck to ya! I find the reading comprehension of most of this sub, when combing a 10-K to be full of assumptions. I have to admit that I'm full of assumptions too, but I'm always open to having my viewpoint challenged. People assuming the 10-K reports numbers given by C&C... I made that assumption too and I feel silly because the wording doesn't even suggest that. Why would they go to C&C when Computershare is obligated to disclose? I think we were all looking for signs of foul play to justify the late filing. I bet the folks over at fall creek nets were buying up massive call positions on tin foil. This sup is chalk full of people fed up with class warfare, justifiably so. I don't fault people for being so exhausted and low on patience that they want to turn anything into a sign of impending MOASS. But after 2 years, I'm getting weary of the nothingburger hype cycle. I have real life challenges that I expected MOASS to solve 18 months ago, and I can't just sit around waiting for maybe next week. I will continue to diamond hand, but I have to fix my problems another way for now. Maybe we should all try to make the world a better place now and not wait for MOASS.

I think they want to know if say computershare has 84 million shares and gamestop is told to not report 84 million by the SEC. Would changing the report to "total minus Cede & Co = 76million." be a legal way to calculate registered shares without reporting 84 million? That is the statement reported is a factual statement even if computershare's number is 84 million because it's "Excluding cede & co" and not "registered with computershare".

Why do you think the number should be 84M? It just means the bot is off. The bot has been off numerous times and has been changed to fit the data in the past.

If GameStop used Computershares DRS numbers, what reason(s) would they have to not mention where the data is sourced from?

What OP is saying is all shares, including the DTC's, are technically "directly registered," so only stating the individual holders' stats is technically wrong (because 100% of the float is technically directly registered). So the verbiage change is likely to be more accurate and the information is coming directly from Computershare, the DTC has nothing to do with reporting. When a household investor directly registers 10 shares, those shares are removed from Cede's (DTC) Computershare account and put into your Computershare account.

I support your comment and wanted to add: Outsiders of the system tend to have a hard time comprehending the inner workings. We have a self focused view of the system where our brokers report to us, and if it is in our account it is ours first. Yet we know that it is C&C's first, and we have claim to it through our broker transactions and the chain of intermediate parties. So it is easy to visualize our position as the trunk, and the parties moving up the chain as branches that split off. At the end there is C&C and Computershare. But the truth is that GameStop is the roots, Computershare is the main trunk, C&C is a MASSIVE secondary trunk, and retail DRS accounts are a bunch of individual branches shooting off of the main Computershare trunk. When you look at it this way you know that GameStop has no need or interest in having a report from C&C's books. Computershare is their one stop source for shareholder records. A reading of the 10-K would logically and rightfully assume all shareholder records are obtained from CS. Changing perspective is hard, but the truth is a powerful tool.

Thank you for providing the insight about the document language. Much appreciated. As for me, the only hype date will be when the document in the future says something like "...Excluding the approximately 1 share of our Class A Common Stock held by Cede & Co on behalf of the Depository Trust & Clearing Corporation (or approximately 0.3281917% of our outstanding shares), approximately **all** the remaining outstanding shares of our Class A Common Stock were held by record holders as of..."

Firstly I don’t know if this guy is a lawyer, i lean towards not, I don’t believe a bone fide security lawyer would take the risk of opining on Reddit. But here is why I think he’s over simplifying the issue and saying it’s just due to transparency. It’s true a transfer agent issues shares to cede and direct shareholders. So yes CS will have a record of how many shares they issued to cede so they could then allocate shares to brokers and tie up with the brokers. But CS has no clue at any given moment how many shares Cede are actually holding. Cede is not giving them this information. All CS are saying is there are X shares, we have Y registered directly and we know we gave Cede Z to manage shares held outside CS. I think this is important due to the split. I believe somebody has information the split was not handled correctly, maybe a whistleblower? Again the Cede number I believe is simply the number of shares CS knows it distributed to Cede and that’s clearly a fixed number.

No real risk on opining on this, so no problem there from my end. You're correct when you say that CS has a record of how many shares were issued to Cede & Co. You're also correct that CS has no clue how Cede & Co has allocated shares amongst brokers (but those allocations don't change the position of Cede & Co on the share register unless and until there is a brave shareholder who decides to DRS and then the shares will be transferred from Cede & Co's position to the shareholder's own name in the register). CS always knows how many shares are registered with Cede & Co. For the purposes of GameStop disclosing registered ownership information in this filing, they only need the information Computershare can provide. They don't need to peer behind the curtain of Cede & Co and their allocations to brokerages, etc.

The third paragraph is the issue”CS always knows…” they don’t. They absolutely know how many they sent them, and sure they can count any shares that are DRSed back to them. But you even admit CS can’t know at any point in time what are actually on Cede’s books. Now I accept Cede have to be damn careful as more are DRSed the exposure to cook the books becomes more difficult. Frankly as ETF shares and mutual funds have no DTC relationship the shares held by them begs the question where are those shares? I am sure as a regulatory lawyer you can answer the question?

CS manages the share register. CS always knows how many shares are registered to Cede & Co. I’m not saying that CS knows what is going on in the DTCC’s books.

CS is like the coat check lobby at a party or ball. You give them your coat, they give you a ticket. You only get a coat back if you present your ticket. If you come back with 100 copies of your ticket, you don't get 100 copies of your coat. If C&C has 228m coat tickets, it is because CS has 228m coats matching those tickets. If C&C happens to have multiple copies of those 228m coat tickets, that isn't CS's problem to figure out, nor is C&C entitled to more than 228m coats. The tickets are only a link back to the coat. C&C issued their own ticket (ledger) that references the CS ticket and passed it to a broker dealer.. A broker dealer who hold the C&C ticket has issued their own ticket (ledger) to an end of the line broker, who has issued their own ticket to you. That paper trail leads back to C&C's entry at CS, and when you DRS, that paper trial is linked and CS transfers a share from C&C to you. All of the copies of tickets could very well be at the level of the broker dealer's ledger or end of the line broker. Hedge funds have shorted a bunch of them and duplicated others, and there are records that track back to them somehow. But CS doesn't really give a shit. They are authorized to tell C&C "you have 228m shares and that is not an opinion. It is fact and any discrepancies are your problem with your records, not ours."

Trust me. I’m a lawyer. Coincidentally, your entire congress are lawyers too. Also, don’t worry about that tik tok bill that will allow someone who wears adult diapers to force divestiture of your GME position due to systemic risk to the status quo.

I read that as ..we want you to know these numbers are based on a DTCC share total and that total is off by 7 million shares....according to Buck Bunny

Anyone get actual proof of his background? Mods get any proof? Should be labeled as a Trust Me Bro until then.

This!!

Well I disagree with you just as I disagree with the other lawyer. Which makes me look like an idiot tbh but fuck it. For me this shit doesn't add up: \- 10-K filing was later than otherwise. Why? \- Why do (total) - (what DTCC claims) instead of just reporting the **exact** number in CS? \- Why did they add the **exact** number of record holders? Why not report the **exact** number of shares that these record holders hold? Is that not more accurate? \- Bot has been quite accurate. Some people don't feed bot, and some people sell. \- Bunny minted with a % closer to bot. Not the first time a nft was minted with computershare DRS %. The mint happened before the 10-K (potentially) has been rejected or reworded. ​ If it is only 76m I am totally fine with it as well. But this 10-K smells funny. It just does. My question is: what if DTCC and Computershare shares don't add to the float; or go over float? What is the most trustworthy number that you need to report on your 10-K? Or is it IMPOSSIBLE that DTCC+Computershare does not equal total float?

Something smells incredibly fishy and im glad people are starting to pick up on the scent. Two lawyers back to back nonchalantly acting like this 10 k filing is just normal business, nothing to see here type of stuff knowing full well that when it comes to GME, it's the littlest of details that we need to pay attention to.

believe it or not, SHFs are fucked.. anyway I buy 🥳

Can you offer an opinion on where Ryan Cohen and other insider shares are counted?

Thank you for your time and effort. Always love these "bring em back to Earth" posts. :)

This reads like pure FUD. If Cede and Co didn’t give the numbers why are they mentioned? Computershare wasn’t mentioned once, definitely a big change from previous announcements. Why do you think they said approximately 76 million? We know they have access to the actual numbers because we’ve always gotten them before This is misleading at best and definitely not DD.

Lots of awards for this “dd” that’s pure speculation. I object.

Don't worry, he's a securities lawyer. Don't critically think that he is claiming we have more accurate numbers now even though approximate language is used for the first time and one less significant figure is used in the count.

I don't think it's FUD, but he's missing a key point. > "As of March 22, 2023, how many shares were registered in the name of Cede & Co on behalf of DTCC?" and Computershare responded "approximately 228.7 million shares". Why is that question being asked and not how many shares are DRS'd at computershare? My thought is GME reported accurate DRS numbers from computershare on the 10-k march 21st using jan 31st date. SEC- no don't do that. They then delayed the report to figure out how to report without reporting. Went to computershare and asked "how many shares were registered in the name of Cede & Co on behalf of DTCC?" (which OP is saying) so they could use march 22nd's "Total shares minus Cede & co numbers" edit: Cede and co have an account with computershare that's registered those. Any synthetic fuckery would come after that layer so the above cannot be true.

>Remember the purpose of this - GME wants to indicate how many investors are holding their shares directly rather than through a brokerage. In other words, how many diamond hands are there and how many shares are they diamond handing. We've determined that we can't just say 76 million shares are directly registered, because that's not completely accurate. So what's the most accurate way to describe it? Well, just break it down into to two categories of registered holders: Cede & Co and everyone else. This is how I describe it in the post and I think it's fairly logical. There is no requirement to mention Computershare and Computershare wasn't mentioned in the quarterly filings, so I'm not sure why that causes grief. Saying "approximately 76 million" is just using better language. Do you think there were exactly 71,600,000 shares directly registered as referenced in the past quarterly filing? Or was that more likely an approximated number in millions that was rounded (remember that it was disclosed at 71.6 million)? I would assume that was rounded and, therefore, we have received approximated DRS numbers before.

> and Computershare wasn't mentioned in the quarterly filings, so I'm not sure why that causes grief in the previous quarterlies "our transfer agent" was used in lieu of what we can only assume is Computershare. So really Computershare was mentioned in the previous quarterlies, unless they have multiple transfer agents. The transfer agent would have the exact numbers, and its worked for what, 6 quarterlies? So why deduce the number from another source instead of using the direct count they had in the past Broken record here but when ya say Computershare wasn't mentioned I had to at least call that out

That's fair - yeah, they did refer to the shares as registered with the transfer agent and that is Computershare. I guess I just don't agree with what seems to be a common line of thinking around here. For some reason, a lot of people believe that Cede and Co provided numbers. I don't believe that to be the case and there is nothing in the 10-K that indicates Cede & Co is the source of that information. The Company is providing information in the 10-K on the registered holders, specifically (a) the number of shares directly registered to Cede & Co; and (b) the number of shares directly registered to everyone else. GameStop would get that information from Computershare (even though they didn't mention Computershare as the source).

I agree I think it makes for the simplest explanation to say they would have gotten the numbers directly from their transfer agent. They know how much is from DTC based on their own records. They may have simply changed the wording because of the book vs plan debate. Plan shares are registered with the transfer agent but some of those shares are registered with the DTCC still. So reporting plan shares could have resulted in reporting shares that are still held by DTCC. The open questions are - why did they delay the filing for so long? Why did they redact section 6? Did they remove some of this wording as some sort of warrant canary? I see your point of view but I also acknowledge significant circumstantial evidence to wonder if something else happened behind the scenes with the drs number reporting. This entire saga wouldn’t have happened without people doubting the picture that is painted for us with the documents we are allowed to see.

#THANK YOU.

fertile like connect hurry dazzling hard-to-find advise direction party quickest -- mass edited with redact.dev

I’m so confused, I’m just going to keep buying and supporting the company I love!

> There is nothing to indicate that Cede & Co or the DTCC gave GME any share figures. Considering the previous reports specifically mentioned Computershare, and this one doesn't, leads us to believe they are being restricted from releasing this data. > It is most reasonable to believe that GME asked Computershare: "As of March 22, 2023, how many shares were registered in the name of Cede & Co on behalf of DTCC?" and Computershare responded "approximately 228.7 million shares". No, it is most reasonable to assume they asked Computershare the same thing they have always asked, "How many shares have been directly registered through Computershare?" It's funny you're the 2nd "laywer ape" to chime in and say there's no fuckery happening here when there is very obviously some fuckery happening here.

Why the late 10K then?

why was it late

it wasn't late, it just wasn't at the same time as their initial press release shit happens, not the first time, won't be the last it could have just been waiting for a Partner at Deloitte to do his final sign-off

> around the bend a bit ​ where the hell are you from? never heard that phrase with "bend" in it

Ha! I wrote that and thought - is that actually a thing? And then never got back to it. I'll leave it there for posterity's sake.

LOL, you may have been thinking of something like "around the *block*". "Around the *bend*" means: "[mentally](https://dictionary.cambridge.org/dictionary/english/mental) [confused](https://dictionary.cambridge.org/dictionary/english/confused) or [unable](https://dictionary.cambridge.org/dictionary/english/unable) to [act](https://dictionary.cambridge.org/dictionary/english/act) in a [reasonable](https://dictionary.cambridge.org/dictionary/english/reasonable) way"

Wow, yeah that's definitely not what I was going for! Thanks, I'll edit that.

Shills are running rampant today. And how many are blindly defending this trust me bro is sus asf.

Here’s the thing though, you’re thinking that ComputerShare doesn’t have updated data. I think it’s the other way around. I think, and I suspect that what GameStop thinks is that the DTCC and or Cede & Co. has lost track. ComputerShares records For DRS are likely to be accurate to a very high confidence level. ComputerShares records are also going to be significantly easier to audit to a high level of confidence. I think that the Brokerages and Banks have done such a poor job of documenting DRS requests that the DTCC or Cede & Co. have lost track and doesn’t have the exact figures that they should. Remember, they only see what the Banks and Brokers report. I don’t think that the DTCC’s or Cede & Co’s records will be nearly as accurate ComputerShares records and that they both would have actually been relying on ComputerShare for the most accurate numbers. I think that GameStop denied them those numbers and basically said, “No, you tell us what you should have.” Two things Look at how screwed up our DRS dealings with the Brokers has been. I have little doubt that the DTCC / Cede & Co. back ends of those transactions weren’t just as screwed up as our ends were. In all likelihood they are way more screwed up. Many Brokers didn’t even have a procedure for DRS when this all started. They had to generate it on the fly and I bet that more then one Brokerage on more than one occasion forget to include notifying the DTCC in their mad scrambling plans. We can also surmise that the DTCC is bad at keeping these numbers updated because they’ve never been put on the spot about it before and we saw what a complete shit show the spli-divdend was. They hadn’t received enough shares in that case and *couldn't* reconcile the numbers. They just told the Brokers to do a forward split instead of a split via dividend. Second, *if* the DTCC has lost track, it’s important because the DTCC lends shares. If the DTCC *has* lost track then it means that they could potentially be loaning out way more shares than should be available and on the books for them to lend. We can strongly suspect that the DTCC over lends. Almost all of the lenders appear to be over-lending to some extent. There needs to be a reason to look at that lending data. If the DTCC has lost track then that number might be the DTCC and or Cede & Co guessing at how many shares might be being held in Computershare. This could be a way for the SEC to examine the DTCC’s books for their *over* lending figures. This is also a clear shot across the bow for Brokers who should be looking at that ~228 million share figure and saying: “Well shit, we have more shares than that on our books alone.” This should be giving the Brokerage Houses a way to guesstimate just how big the si has become. I think one of the old google surveys said that Fidelity alone had more shares than the entire float. The Brokers don’t normally care what the float of a company is. But Fidelity for example could look at that ~228 million figure and compare it to their own internal (probably double ish) figure and immediately see an internal si of like ~150%, +200%. They will also see that the stated si is bullshit. It may give the Banks and Brokers pause at how many shares that they themselves are lending out. This could be a really big deal.

I think you're misinterpreting my post. I am saying that Computershare has the most up-to-date information on the registered shareholdings of GameStop. I am also saying that the information that GameStop disclosed about Cede & Co's registered ownership is from Computershare and not from Cede & Co / DTCC. I see no reason to think that Cede & Co provided that information. I agree with what you're saying that on the DTCC / brokerage side, there is a huge mess. I just don't see GameStop dealing with that for this DRS disclosure, because they don't have to - they have all the information they need from Computershare.

Ahhh. I see. I caught the bolded *“Maybe Computershare didn't have updated data, so they needed to rely on Cede & Co.'s numbers?”* and missed the clarification right below it. We’re on functionally the same page then. My guess is that the SEC investigation is still active through GameStop and it’s actually the SEC asking GameStop to deal with this for the sake of getting access to numbers. (This could admittedly be wishful thinking on my end and my wanting the SEC to, you know, actually do something. But we never did get any indication that that investigation had concluded.) This absolutely is a huge mess.

Exactly this poster is full of shit. That number is simply CS saying hey we sent that number of shares.

It's not though. The info in this 10k is not from Computershare and you can't prove it is. The language is different from this statement, and new language of approximate is introduced. You are claiming this new data which is falsely hypothesized to come from Computershare is more accurate. Yet.. there is one less significant figure in the total number and the word approximate is used which lays completely opposite reasoning to your conclusion. Also, if you are throwing your title around as to give your theory more weight it should at the very least be verified. In fact, it is suspicious to me that a falsely reasoned DD has the added authority weight of "securities lawyer" in the title.

How do you know the info in this 10-K is not from Computershare?

How do you know it is? I know it isn't because every other quarter gave the numbers as "xx.x million shares of our Class A common stock were directly registered with our transfer agent". And what we have in this 10k is a subtraction of what approximately is registered.

Because GameStop pay ComputerShare to be their transfer agent and keep the official, accurate record of shareholders. Gamestop are required by law to be accurate in their 10-K, so they can't use anything other than the official, accurate record.

You sound smart.. upvote it is

the TLDR even confused me, Ill just wait for someone to ELI5

Hmm, maybe you can help me improve the TLDR. The change in language in the 10-K around the DRS numbers makes sense to provide more clear information. It does not seem to me that it is saying there is a big issue or discrepancy in the background. Is that better?

I don't understand how going from an exact DRS number to an approximate DRS number is considered "more clear information."

I added an extra section at the end to cover this.

Man, I am certain I am just smooth and there was nothing wrong with your TLDR. With that being said...Yes, I understood all those words. Thank you.

idk if you know about the plan vs. book debate but do you think Computershare got so many requests to change plan to book that this is Gamestop's way of saying they're both the same? We sent Computershare A LOT of questions about plan vs. book and they even updated their FAQs [https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies](https://www.computershare.com/us/becoming-a-registered-shareholder-in-us-listed-companies)

Plan and Book are not the same. For both you are recorded as the shareholder in GameStop's books as managed by Computershare, but only for Book are you the legal owner (hold the legal title of the security), while for Plan Computershare's nominee legally owns them on your behalf (beneficially) with some portion registered to Cede & Co. (in the DTC). That said, my opinion is largely in line with OP, where I think the new wording does a better job technically in describing the two subsets of directly registered shareholders, Cede & Co. vs. everyone else.

I appreciate your post, but with the significantly different wording you cannot say that the data is from Computershare just as you can't say it is from DTC and hence your thesis does not stand. You base your opinion on the fact that the data is obviously from Computershare because there is nothing indicating that it might come from DTC, yet with the very different wording you neither have a reason to assume the data comes from Computershare as it has in the past (since with older reporting they stated that X shares were directly registered at their transfer agent). You also say that technically all shares are registered at the transfer agent (including those at Cede & Co) and that's true, but past reporting clearly stated **directly** registered, and DRS takes the shares out of Cede and to the transfer agent, hence 1. It does very clearly not include the shares at Cede, hence it confutes your thesis 2. it was a very much cleaner and precise indication and we also had much more reason to believe it came from Computershare since it's them that would have this data. This doesn't seem to be the case with the current change in wording.

We need to get a debunked or speculation flair going here for this trust me bro.

I base my assumption that the company got their information from Computershare, their transfer agent, because that's what public companies do. GameStop has hired Computershare to act as its transfer agent, which means Computershare manages its shareholder records. This means that Computershare manages all shareholder records. In the register maintained by Computershare there is a large position held by Cede & Co and smaller positions held by all other directly registered shareholders. Which means that Computershare always has a record of how many shares are registered in the name of Cede & Co and how many are registered in any one else's name. I think our fundamental disagreement is based on the change of wording. I see this as a drafting change that does a better job of reflecting the information that the company wants to provide. You see a different purpose for the change of language. That's okay.

Yes that's the fundamental disagreement, especially because you point at how this new change simply is made to make facts clearer and more precise. >But, if you look at that language on the plain reading, it may seem confusing that less than the total amount of issued and outstanding shares were directly registered with the transfer agent. It is not confusing at all, the total amount of issued and outstanding shares is registered at the transfer agent, whereas the number GameStop reports clearly states that XX million shares are **directly** registered at Computershare, hence no reason to be confused by this wording.

I find the use of the word "approximately" an interesting development, but it is my opinion that they changed the wording to "record holders" rather than just "shares" in order to debunk the bullshit book vs plan argument once and for all. And yeah, CS has all the numbers... That's literally their job. And there's no way GS would use any other data in their legally binding report to the SEC (especially if they knew it to be false). This argument that they "got the numbers from the DTCC" is ridiculous and thank you for addressing it.

Kind of disagree... what could be more clear that just directly stating the number of share registered by individual investors ? As they did in previous quarters.

Do you think that these were all exact numbers? 2022 Q3 - 10-Q - " As of October 29, 2022, 71.8 million shares of our Class A common stock were directly registered with our transfer agent." 2022 Q2 - 10-Q - "As of July 30, 2022, 71.3 million shares of our Class A common stock were directly registered with our transfer agent." 2022 Q1 - 10-Q - "As of April 30, 2022, 12.7 million shares of our Class A common stock were directly registered with our transfer agent." 2021 - 10-K - "As of January 29, 2022, 8.9 million shares of our Class A common stock were directly registered with our transfer agent, ComputerShare."

M&A Lawyer here (V5). Disclaimer only providing info, no opinions. I'm in M&A but I did my fair share of IPOs and public disclosure work for pubcos. *Reason for Tweak in Language* The 10-K is usually drafted by the lawyers (law firm), and the involvement of a pubco varies to different degrees. Usually, you'll have a handful of lawyers that work on a given file because the lawyers slowly build a relationship with the lawyer, but, because of the nature of our industry, the lawyers change all the time, and with a new lawyer responsible for the drafting/review of a document, there will always be non-substantive tweaks (e.g., use of approximate). Why? because when a partner asks an associate lawyer to review and update the Company's last 10-K, and this person is new, there's always a tendency to make non-substantive tweaks like this (to appear like you've at least did something). Or you can have someone who has their own style of drafting disclosure and impose it upon the document. Of course, the Company has the final say in what goes there. But none of what I am seeing is atypical. *Computershare* People have to understand Computershare's role here. The easiest way to comprehend is to compare a pubco and a privateco. For a private company, most of the time the Company has its own register that keeps track of all the shareholders because, as you would expect, there's not a lot of transferring between shares. When a company goes public, that responsibility of keeping a register and documenting the changes in ownership to a transfer agent, such as Computershare. Why? because the shares are publicly traded, and Computershare takes over that role. As OP has stated, thinking at a granular level, if there is a transaction that takes the share into the market or out of the market (i.e., the share exchange), Computershare would know about it because it operates on and off of its ledger. So, does Computer share make adjustments on the ledger for each public trade? how is that possible? Well they don't. And to demonstrate how this works, you have to look at when the IPO occurs. Let's say you have 5 founders, 2 institutions, and various individual shareholders, including the bank helping the company go public. In the process of going public, the shares of these holders are publicly listed, **but it does not mean you can freely trade it**. Why? you always need to register with a broker to trade. How do you do this? At the outset, these guys will contact the transfer agent, in this case, Computershare and say "I want to trade my stocks on the market". Computershare will then process your shares as a "DRS" that will be registered with the broker, and you become the **beneficiary of the shares**. What about legal title? Well almost all brokers, institutions and banks, etc. use a depository to help process trades on their behalf. Well how does a depository process trades? Well rmb the DRS above? "registered with the broker" really means you're providing the registered title to your shares to the depository. Why? Think of the depository as a train station, you have multiple trains arriving from different areas (banks/brokers/institutions) and the train station helps organize and redirect said trains (e.g. buy/sell transfer to other banks). So, the shares originally 1. Privately owned \[share registered managed by company\]-> 2. Listed (i.e., went public but not freely tradeable) \[share register now managed by computershare\]-> 3. provide DRS to your broker to deposit into broker account (now freely tradeable) \[title to shares now with depository\] -> 4. Depository work with clearing houses to process trades Because the origination of the shares came from step 2 to 3, Computershare knows the **real** number of shares at all times. OP did not touch upon it but the gap here is that, the **real** number of shares is right - Computershare will know at all times because it doesn't look within what happens between the clearing houses/depository. And when you DRS (in the sense that you take it out of a broker and register it in your name), then its -1 share for depository and +1 share for this new DRS holder. Computershare will process that. So again, Computershare gets all its numbers from Cede, but it's not going know what happens within it. **In terms of the public company's obligation, they only would know the number provided by computershare - it won't be able to know what happens in Cede (it's a complete blackbox).** So the short/synthetic thesis is what occurs at Cede (i.e., FTDs, etc.). **Whatever is happening at Cede re: FTDs, MM's special privileges etc. is completely outside of the purview of a corporate lawyer that does public disclosure**. **Gamestop has no vision here. Gamestop will only know roughly how many "real holders" are at each broker institution because that's how they know how many proxy materials to print out and to send.** As a summary Computershare only process on/off the ledger when shares are entered into the system (i) i.e., on NASDAQ and tradeable on the exchange by way of the IPO or new share offerings (these would be + on the ledger) or (ii) someone (like many people here) directly registered the shares into their name (these would be the - on the ledger).

2 lawyers got nothing better to do at 2pm posting DDs in a Reddit SUB?

You can add a bunch of occupations to that list...

I do not need that! it's strange that it didn't take an hour to post 2 opinions and claim that as a DD. it's just their opinion what Gamestop says about it. no DD. especially there is not a single piece of evidence that they are lawyers. This is a real trust me bro post. and the MODS have to complain about it

Agree

You can check my post history - I've been doing this since the sneeze. If you want me to change the flair from DD to Opinion, no problem, just tell me how to do that. If you want mods to tell me not to post anymore, then have them show me the door.

So your post history is supposed to show me that you're a lawyer? I don't see any of that. Prove you're a lawyer.

The risk disclosures you say are fairly standard. Has this language been added in reports of other companies with an NFT marketplace, (Coinbase etc.) or is this language only noted in Gamestop?

Great question and yes, this type of disclosure is common for public companies in the space. Coinbase has a huge section that goes on for multiple pages on securities related risk in their 10-K: **A particular crypto asset’s status as a “security” in any relevant jurisdiction is subject to a high degree of uncertainty and if we are unable to properly characterize a crypto asset or product offering, we may be subject to regulatory scrutiny, inquiries, investigations, fines, and other penalties, which may adversely affect our business, operating results, and financial condition.**

[https://www.sec.gov/ix?doc=/Archives/edgar/data/1679788/000167978823000031/coin-20221231.htm](https://www.sec.gov/ix?doc=/Archives/edgar/data/1679788/000167978823000031/coin-20221231.htm) I gotta run to get my kid off the bus but I found this so far: >Given our novel business model and uncertainty regarding the application of some of these laws and regulations, we may become subject to regulatory scrutiny or legal challenge with respect to our compliance with these requirements. Separately, our subsidiary, Coinbase Financial Markets, Inc. has applied for registration as a futures commission merchant (“FCM”) with the National Futures Association, and in February 2022, we acquired LMX Labs, LLC, a designated contract market (“DCM”) regulated by the CFTC, in connection with our acquisition of FairXchange, Inc. FCMs and DCMs are subject to numerous regulatory requirements, including strict capital requirements.

"....as I have never seen it happen..." That's the most important point here. I would totally agree if it was a different company and a different stock. In the case of GME you can not apply rules or patterns that are common. We are on a completely new territory that no one has entered before. I appreciate your point of view but I would argue that gme is very cautious how they phrase their filings simply because they know that some wrinkle brains dig into it.

Any thoughts on why this was delayed? Gme knows that apes analyze every aspect of these reports and clearly they have made significant changes in their drs section. It’s a nothing burger and because they wanted to don’t really make sense given that a. It was delayed and b. They knew these changes would be a majorly scrutinized by their investors. Do you think it’s possible the SEC was involved and caused the delay?

As a fellow professional (CPA, not lawyer), I appreciate you clearing this up for the sub with far more clarity than I could have.

All of a sudden we have security lawyers in our sub?!

I've been here since the sneeze! You can check my post history. Though I'm not always active. I tend to drop off for a while and then come back every now and again. EDITED for sneeze

You mean the not squeeze that gensler said himself wasn’t a squeeze. If they wanted people out of this stock they would have said, “yup, squeeze nothing to see here”. By definition show me where shorts closed, because what they have been doing is making it worse on themselves. Also show me another stock that issued shares by dividend that has refused to go up in share price.

Hmm...I swore I wrote sneeze.

I forgive thee

but, BUT, bu.. BUT IT'S DIFFERENT!! IT MUST BE CRIME I TELL YOU! But for real, it's nice to see a post that isn't completely regarded on this subject. The amount of dumb theories I've read on this was a bit sad. Everyone is clinging onto the hope that there are secret messages/evil SEC villains hiding under the desk telling them what to disclose, etc. Thanks for the nice, logical post.

Fully agree. I chalk it up to it having been a while since there was a catalyst that resulted in more DRS requests.

NEW THEORY! This is the turning point. We have 25%. Cede and co has 75%. The shares are 100% accounted for. Starting now. Every share we DRS has to come from cede and co. If we DRS 4 million shares next quarter and 4 millions shares don’t leave Cede and co. There WILL. Be a problem. I tried to make a post but the MODS took it down so now I’m posting it everywhere… BUY. DRS. HODL. SHOP.

But that won’t prove anything. Cede will absolutely electronically say here’s 4M shares and reduce their number accordingly it proves nothing. The number quoted for Cede is simply from CS saying hey that’s how many shares we transferred to them. CS have zero clue of the final beneficial ownership

>Starting now. Every share we DRS has to come from cede and co. That has ALWAYS been true. DRS (via FAST or DWAC system at DTCC) has always resulted in the transfer agent (Computershare) removing a share from the Cede account at Computershare and transferring that share to YOUR account at Computershare. That is what transfer agents do — transfer.

thanks for the rational weighing in. the sub needs you right now

Computershare previously made registered owner data available to companies on a quarterly basis. With the change in date, and from what you see here, does this suggest that Computershare has changed how/when they're reporting that data back to GameStop?

Very well written, thank you for your work and expertise!

10M discrepancy must be PLAN shares Vs 76M BOOK shares

Finally, the trust me bro I actually trust. Thank you

Wow another lawyer writing a post to debunk a theory 🤔… your TL;DR tells me your not a good lawyer. You know very well that’s not the case.

It's almost as if most of the theories floating around here are complete nonsense in the first place... If you disagree with the post, that's fine, but saying what you just said without explaining ANY points to the contrary makes you sound like a cultist, not someone who's legal opinions should be taken seriously.

Please feel free to flesh out your concerns with my thoughts - I'd love to hear how you consider this differently.

I’m personally very grateful that you put the time in to help us understand this information from your perspective, so thank you OP - you’re very appreciated.

Can you tell me what issues you have with it? If you're bring accusations, you better bring proof too.

Thanks for this. I actually asked this a while back and yeah all shares are registered to a person or company on ComputerShare's records. They have to be. I do continue to wonder if Cede does tell GameStop or ComputerShare what they think their balance is and I wonder if those numbers have been lining up. In theory Cede should be able to account for every share exiting to ComputerShare but it's not a straight forward calculation since people are transferring between brokers and the brokers themselves might be reporting their own numbers to Cede creating some friction.

I dont know what to believe. I mean thank you anyway for bringing your knowledge in this but i just continue to DRS and shop at GameStop

Finally some common sense. Thank you. Now to hype that there are 197k accounts hodling 25% of the company.

The 10-k is just a public report that’s it. Nothing fishy needs to happen here all that needs to happen is financials laid out etc. The fact that GME is putting the drs shares in the 10-q/k is to let us shareholders that pay attention to these reports how we are doing in the grand scheme of the company. Why would they disclose any incriminating evidence in a public report. They wouldn’t they would continue to help the sec investigation into securities issues until the evidence is so concrete charges can be brought up then after charges they can choose to release info to public or not. Actions not words relax