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accepted new short sale orders in reliance on an easy to borrow list ("ETB List") after having learned of facts indicating that such reliance was no longer reasonable and therefore ... security could be borrowed and that the locates were inaccurately documented with an ETB List locate reference, and (2) in certain instances, used data that was more than 24 hours ... construct the ETB List, which, at times, resulted in securities being included on the ETB List when they otherwise should not have been. The Firms agreed in the SHO Order