SPRING BREAK

NEXT POST MONDAY NIGHT OR most likely Tuesday...all be safe....correction is nigh...

D

CONSUMER CONFIDENCE DATA

NOTES

A close above the 200 WEEK moving average which has flattened, they tend to support a move.....yields maybe not in danger zone, what would a mass exodus be like......

IF homes are the fuel that stokes the fire, what in bleep is burning? avg Joe is upside down by $70K....why let's just forgive principal.....won;t that reinforce lowered home values of which are on the books at FACE? big lod sham....uncle wiggly's elixr being sold ...

D

ACT I, EXIT STAGE LEFT?

Inquiring minds want to know.

FUEL FOR THOUGHT

Housing is the FUEL which FEEDS most recoveries, yet the housing data shows this segment of economy at or near worst levels of the crisis if not history. It now takes over 14 months on avg to sell a property.

But the FED has not signalled it's even close to changing it policies, and that has emboldened speculation without worry about excessive valuations or the lack of substantive data to show the V shaped rally = an economy on steroids.

Going forward, those prices may climb to near SPX 1250 (area near Lehman collapse) it is hard for me to justify confidence in the underlying economy.

STocks rose during the dotcom era, even though most of those companies did not have viable business plan, they did rent space and buy computers and furniture and hire workers.

What pray tell is happening during this particular juncture that looks like a sustainable recovery is here?

D

WHY ARE SO MANY BULLISH?

For now rates are contained, but in an uptrend, breaking OUT here mightusher in arguably much higher rates and put "recovery" at grave risk.

There is and percieved a FED backstop to assets and debt, with most figuring FED will leave rates at ZERO for years if they have to. (read Noand piece I posted)

This is the paper asset game, but a bubble has been building in debt and this is the kind of recovery that creates little jobs and lasting recovery, which we ARE witnessing.

The only thing keeping it going is unlike Greece we have the RESERVE CURRENCY, so when many experts talk of recovery and LASTING ECONMIC EXPANSION, IMHO what they are really talking about is the FED's seamingly unlimited capacity to backstop the market and risk with NO END IN SIGHT.

It would NOT surprise me to see the market down the road rise to NEW HIGHS, even as overall volume has waned since March of 2009.

Short erm corrections are normal and may be here again, but as far as I can tell, the game has not changed until an ACCIDENT seems to come out of nowhere...and the smoke clears and it is seen for what it is, a mirage and the problem has been made worse, much worse.

FInancial stocks ahve been rallying, breaking out, but the value of assets held are on books at unreal values, profits are not real.

D

"RESTORATION OF KING DOLLAR"

NEW DOUG NOLAND WRITING @ prudentbear.com


"Bond yields had diverged too much from the reflationary realities evidenced by inflating equities prices. The bond market must look at stocks – and central bank dovishness - with rising apprehension. But at least thus far, rising Treasury yields have not incited a widening of Credit spreads.

I believe U.S. reflation will be in jeopardy when a jump in yields occurs simultaneously with increasing risk premiums and waning Credit availability. And I wouldn’t be surprised if such a scenario unfolds in response to renewed dollar weakness. Considering the backdrop, call me a King Dollar skeptic."

IT'S SPRING TIME!!!

THE NEW NORMAL

Rally attempt faded as the day wore down, so we could have formed a ST top, that is not to say prices fall out of bed.

People are SO underwater in their homes, and some banks are offering deals including "principal forgivement" so how does the next guy feel if he pays his mortgage and does not get a prinicpal reduction, dude you gotta lose your job for that....am I the only one feels there is some sick twisted shit going on.

The gov is trying to buy votes with a few pennies thrown to the unfortunates...NONE of these programs will help very many people, it all for show with no go.

We are bass ackwards again....you revive the economy wth jobs, jobs bring more spending, more spending brings in more tax revenue.....no we should raise taxes, increase government spending and handouts.....my friends, this is how you get bought off.....and feel attached, beholdin...and in need of the gov teet....they buy us off with their agenda...votes...grow even bigger and fatter, if something doesnt change...we're headed for the new 3rd world

D

WRONG WAY FRED

CORPORATE PROFITS FELL 6.9% IN 2009, market rose 70%. Profits ARE overstated because of mark to market rule being abolished and it mistates BANK earnings.....another reason I hadn't believed in the underpinnings of the rally, recovery....it's built on GOV DEBT which I show is reaching unsustainable levels.

Consumer sentiment due out at 1o AM

D

BDI CHART

Observation is that the ROC (rate of change) indicator has fallen below 0 first time since rising above in July of 2009

AN UGLY MIRROR IMAGE

*quick note, Thursday the traffic to my blog was off the charts, welcome to my blog, I will continue to work and offer something worth coming back to.

In 1982 as this chart bottomed out, it set up the GREAT AMERICAN BULL MARKET. not necessarily a TIMING TOOL, BUT IT DOES SHOW A STARK CONTRAST to what we now see......total GOV debt in NO MAN'S land, in nose bleed section....no doubt NEAR "the point on no return".

Above chart provided by contraryinvestor.com and posted on jessee's cafe

The straight up trejectory from 2009 was from combatting the financial crisis andhas put us in harms way of a debt implosion, normal is not where we are.

GOV debt must be paid back....but how can we? Defaulting would mean losing the reserve currency status, printing $'s has fueled the so-called recovery.....but they cannot always control where it goes, and their OWN policy and that of the HEROES FED leads banks NOT to lend.

NOW....on top of what you are looking at above, we are set to UNLEASH a TSUNAMI of debt issuance.......there will come a time where the current rates offered will not be acceptable.

ANY rise in rates will make it even harder to ever pay back the debt, and servicing it near impossible.

I recently read that home sales had slowed because "mortgage rates had risen"....my goodness they are still near generational LOWS....a few ticks take people out of affodability range?

I had also shown last week how each new $ of debt issued generates less and less GDP bang for the buck.....so if you wonder why $TRILIONS have not had PROFOUND effect on economic advancement....that is why.

Internet spoils profit margins for all kinds of businesses, and ran Blockbuster out of business or near brink of, and that means TONS of Commercial locations shut down, costing JOBS, and RENTS. When retailers try to close a sale, they are more and more confronted with the faceless internet shop that will sell for peanuts and ship for free.

Our manufacturing base, also because of direct and indirect gov trade policies, is all but whithered away, those jobs perhaps gone forever. SO WHERE do the future good jobs come from?

How does a $30B jobs bill work in a $14 TRILLION economy? DOES DIRECTLY influencing direction of stock prices create sustainable recovery? FREE MARKETS were not allowed to carry out the natural selection process.

We the people feared NOT the DEATH of the unholy BIG BANKS, we fear their existance and what control and influence they peddle to the government....and MANY of their fledglings are in positions of power and influence.

You cannot borrow and spend your way to prosperity, you can only influence short term trends, and the larger degree trend, the SECULAR BEAR MKT will then resume at some point and has the potential to drive the markets MUCH lower than where they rise to....IMHO

Health Care debate aside, the point I am making is when the MAJORITY of THE PEOPLE speak out as to what they want, and then the government decides what is best for us the MAJORITY and that goes AGAINST our wishes......has the Constitution been soiled?

Now we're on course for an even BIGGER UNSUSTAINABLE government.....and ask yourself how well and efficiently they usually run things?

The reversal day we had Thursday shows we hit a price that attracted sellers, Tops don't usually end with a thud, but corrections can occur at anytime.

Duratek

HAMMER TIME

RED HAMMERS are in place all over the place, leads me to believe along with RED reversal day in SPX a correction and short term top may be at hand.

SPX also fell back below 1169, but maybe 1150 prior resistance will hold.

D

WINDOW DRESSING

Rates still trapped and forming a RIGHT SHOULDER, a breakout from the box I show here COULD have a nasty effect on the markets.

Here comes the END to the quarter, so with big gains in place most MM's will not have much desire to sell off their winners going into WED of next week. This would play out as a low volatility period.

BIG HEADS continue to talk of the "strong recovery" and for now that' all Greek to me, but that is the reality presented and the previous highs not so far away.

WISE MAN GIVES ADVICE

First thing you have to do is HAVE CASH to alloctae to stocks when they fall. I have spotted last 2 bears, I'm good there, but once you come or at least REALLOCATE to reduce suffering in a bear....but must also raise cash when the SIREN sounds and sometime yes get 100% out of stocks......allocate to bonds, commodities etc.....depends on circumstances.

Demand remains strong for stocks, doesn't matter why....my commentary is for big picture.....and it does help me be watchful....as was case in 2007....but technically I do not see red flags as yet....crash could come from nowhere, no one can see that.

Point is, you don't go all in all at once, ease in.....especially when trend establishes itself....so maybe as good friend suggested you expose up to 25%...depends on what you can be comfy with.

This is for those who manage funds themselves, not many advisors every take you out.

If you ease in, if I was wrong at bottom in 2009....I have PLENTY of fuel. I could argue I bought 25% at lows, but then DOW crashed to 4,000....so I buy another 25% at bargains of life......as trend eventually turns up...my first purchase will be in money and I begin to add as trend strenghtens.

This plan makes sense, takes gambling out, big hit mentality will lose you money most of time....and keep you OUT looking for perfect entry.....we don;t have to agree.....but some have been to my blog and suggested world not ending and is now heading to that target perhaps to 1200-1250.....on MOMO, on liquidity.

That may end badly and I'll be on lookout for technical signs, along with my knowledge gained from Lowry commentary and data

D

VELOCITY OF MONEY IS COLLAPSING

It apears to me, when money turning hands SLOWS DOWN like the M1 multiplier shows not a good thing for economy. At same time the MZM stock of money has catapaulted to dizzying heights....my conclusion is boy less BANG FOR BUCK....read mauldin piece.

JOhn Mauldin has a good piece on it here

From 2008 BIG PICTURE VELOCITY ARTICLE

GOLDIES LOOKING REAL TIRED

THIS IS HOME RECOVERY?

AND THIS with 70% PLUS V SHAPED STOCK MARKET VAULT? hey just wait til we actually do grow economy....another fing sand castle!

D

WHAT SHOULD MATTER DOES NOT

■Existing Home Sales Fall to Lowest Level Since June
BANK LOANS OUTSTANDING CONTINUE TO DECLINE
HOME VALUES CONTINUE DECLINE
JOBLESS CLAIMS STILL ABOVE 450,000
20 MILLION UNEMPLOYED or underemployed, those that get jobs accept PAY sometimes 50% less than previous job or more.
RECORD levels getting extended benefits.
GOV deficits Reaching level of GDP

10 year notes yielding UNDER 3.7% !!!

Jobs shipped offshore, banks bailed out but not lending, allowed to have trading desks and goose markets rather than lend money.

ZERO FED POLICY rate insures banks have little incentive to lend.

OBAMA CARE is going to insure health care costs to companies and individulas skyrocket over next several years....as if they wouldn't anyway. If the GOV says it pays for itself be very afraid, and some of funding will come from $500 BILLION of cuts to Medicaid?

I wish stock market WAS the economy, then we'd all be so busy we couldnt take a dump.....

SOMETHING IS UGLY and wrong.....and I see nothing being done, no real changes or regulation to fix problems and the BIG BANKS just got bigger and exert even more control.

Maybe no laws broken? no prosecutions from crisis.....

D

RON PAUL ON HC BILL

RON PAUL TELLS IT LIKE IT IS...LINK HERE

HOUSING RECOVERY

January Existing Home Sales FEB due out at 10 AM this morning
Updated 09-Mar-10 19:32 ET (prior report)
About this release


Highlights
•Existing home sales declined from 5.440 mln homes to 5.050 mln homes in January.
•The consensus expected a small increase to 5.550 mln homes.
•The median price declined from $170,500 in December to $164,700 in January. Prices are now at the same level they were in January 2009.

This is important IMHO, as this low in home prices came just a mont or so before market bottom

D

HEALTHCARE BILL IN 90 SECONDS

SELL THE NEWS? and THE OFFSHORED ECONOMY

ONE DAY...the people will wake up.....and wonder where their freedoms went to....INSURANCE PREMIUMS WILL CONTINUE TO RISE.......why do the bill?

WAKE UP to the new welfare state.......

THE OFFSHORED ECONOMY by Paul Craig Roberts

Another step towards serfdom

OH and the recovery is real....

D

BIG

Those who vote take note, we are being eaten alive by our government. And it just got a LOT BIGGER, by design.... special interest groups applaud and vote......bring us your weak....let the middle class die.

I say thanks Bush you ahole......you made this all possible.

D

WE THE PEOPLE SOLD DOWN THE RIVER

"This plan raids $52 billion from Social Security. It cuts nearly $500 billion from Medicare and doesn’t count the hundreds of billions needed to compensate doctors who treat elderly patients. A portion of this trillion dollar bill is paid for with a government takeover of the student loan industry. The government will shut down private lenders, sell expensive loans to 19 million college students and use the profits to finance “ObamaCare.”

LAW OF DIMINISHING RETURNS

LESS BANG FOR YOUR BUCK CHART

INITIAL SUPPORT ON ANY DECLINE

We'll watch the uptrend line first, so far every pullback has offered a buy the dip reaction...

D

OBAMACARE

LOOKING BACK

Guys, wouldn't THIS TOP RANGE be the area of resistance next? 10,753-10,984

My guess is approaching 2004 top we had the FED beginning to move on rates, they didn't move fast enough and 2 years of BASING, CONSOLODATING initial burst of gains off 2002 lows led to final explosion top into 2007.....as internals were deteriorating.

AS some subs have pointed out, you will get this divergent activity WAY in advance of THE TOP.....friends, this time it will come with MUCH less impact to the labor force.

I see pullback began at 1169 (previous chart), breaking 1150 shouldn't change anything. Extension of the highs based on what I see here would see unlikely, when you figure how far we have come and the economic data is not as vigorous as during this time period....I mean jobs were being formed, economy was HUMMING.....now bigger rally less humming, no jobs.

The ONE standout in ALL THE data is the APRIL 2009 HIGH in the 30 day up and down volume, not consistent with ANY previous BULL MKT this first month high then one year declining trend .


I found out why a new neighbor never finished building his home. The banks just loaned him $1.4 M for our warehouse, he got $710,000 in 2005 for his residence, tore it down, began building a home 2X the size.

He has done NO work on electrical, plumbing etc for one year...now I know why...banks will NOT lend for construction loan....so he must pay out of pocket to complete project.....THIS IS CRAZY.....loaned him $1.4 M for commercial...but nothing to finish home. He has a RESTORATION Contracting business, he seems to do really well.

It is plain sight in charts showing Bank Loans outstanding CONTRACTING, this is one of my biggest beefs...you cannot grow economy without that changing....

We got lots to do to see this little start at revival to catch on, create jobs, allows for increased spending, investment...and on and on...

Best of luck to all, hope for the best....plan for....

Duratek

SPX SHORT TERM SETUP. CORRECTION IS PROBABLLY UPON US

LONGER TERM COMMENTS.

Besides my boo hoo bias for fundamentals, that will continue unless I see real pickup.....stocks are "technically" VERY STRONG with small cap and mids outpacing large cap stocks.....I will probably (don't fall out of chair) go LONG small caps using ETF 3X when correction concludes....If one plays stock market based on fundamental analysis only one will surely lose most of the time. NO sense in lookingback and what you didn't do, we are HERE and NOW so what are opps going forward.

Short Term worries:

% of stocks ABOVE their 30 DMA (day moving avg) hit a LOFTY MT K type 95% !! 80 is considered over bought....extremes always get corrrected....

But as stocks kept creeping higher the % above 10 DMA has been slipping suggesting more selective buying.

Advance decline lines had made new recovery highs at recent highs suggesting healthy advance.

A FALLING VIX is BULLISH, a RISING TREND VIX is BEARISH fear continues to melt away.....dwindling selling intensity = room for prices to move, shoot or drift higher....law of SUPPLY and DEMAND controls all things....especially price.

Not seeing the economic recovery on the STREET, the wild eyed bullishness of avg Joe has not perculated.....a lot of firsts in this rally so a top when it comes may come without the little guy buying the top.

OTHER CONSIDERATIONS:

8 MILLION PLUS lost jobs during the great recession from 2007, that says to me, 8 MILLION not contributing to 401k's, at least not like they were, cash balances at MUTUAL FUNDS at very LOW levels, not supportive of buying.

EQUITY in HOMES blown away, so not supportive to borrowing and spending.

FED POLICY is behind the rally and liquidity flows, and they signal NO CHANGE COMING.

SAFE money nary exists, so are stocks only game left? forcing money into risk usually ends badly....down the road.

Market could consolidate as it did in 2004....it is following that path rather closely.

An unforseen accident or crisis is possible to roil markets but can't always know what or when.

ONLY A SUSTAINED PICK UP IN SELLING would change technical picture, but that is not present today....in fact most TA IMHO suggest the potential for 6 months or longer of current trend...I would target SPX 1200-1250 which is around next FIB retrace as target.

ON MAJOR UNSETTLING consideration of BULL MARKET is the continued DOWNTREND or the "30 DAY UP AND DOWN VOLUME" indicator. It PEAKED iN APRIL!!!! and I had posed this question before to one of my subs and I beleive the answer was this had not occurred during any previous bull market.....but here it is with prices rising from lows at a record.....It had been BELOW a FALLING 200 DMA since JUNE of 2009.

SO the short term picture appears to be leaning for a correction, and the rally may show small caps outperforming its bigger brothers.

Long term yields continue to perplex with 10 year at 3.7% ish, which is rather puzzling considering the 70% PLUS stock market rally, you would think the money comes OUT of BONDS and INTO STOCKS, and if all is going so well, why the FLIGHT TO SAFETY?

AN accident in BONDs causing long term yields to SHARPLY RISE could change everything.

I still consider this a rally within SECULAR BEAR, the claws may be in, but not ripped out...JMHO

Duratek

2 RECENT HEADLINES

"Investors Feeling a Bit Queasy Over Health Care Tax Hikes-

Investors with a steady stream of income from stocks and other assets could be excused for feeling a little queasy as the health care reform measure nears approval in Washington. The latest version of the bill pays for the health care expansion largely on the backs of investors who face a smorgasbord of new taxes on interest, dividends, capital gains and other investment income."

"Dow's winning streak is halted as Greek worries return"

Friends if the DOW was "worried" it would drop by more than 37 points!

Recent comment on blog on housing by SHiller, but main point is as interest rates drop people can afford more house for same payments, and that's exactly what happened with the reckless FED policy of holding rates DOWN for SO LONG......all people were looking at was "what are my payments" which ALLOWED prices to SOAR!

THE FED now has outdone their stupid asses with a 0% policy for g-ds knows how long, and if you pay attention and look back at my housing charts....you can't like what you see...SO FAR anyway....not revived.

This is NOT 1990, or 1998, or 2002....we now have a debt financial BUBBLE BURST and the results are different...medicine the same.

Safe haven is seen in BONDS, the yield nary rising in 12 months as stocks soared 70%...go figure

OPEX out of way....surely we just keep going up no worries...what a booming fing economy we have....what a bunch of suck asses we have at the helm.....BANKSTERS LAUGHING, GETTING PAID, 8 MILLION PLUS Out of work....failed policies in place...same damn mkt gosing game in play..enjoy

D

PLAM ETTO BUG

Ugly chart of day....PALM maybe needs a bailout...

D

FOX STAYS IN HENHOUSE

I sold my commercial building to man who happens to have bought a house in my neighborhood, 4 years ago he began the project, hit some rooting structures, had to almost tear down the enitre house, cost addt'l $250K he paid $710K.

He has doubled size of home to around 8,000 sq ft, outside mostly done, inside needs everything HVAC, plumbing, electrical...and the rest...ending value near $2 M making it far and away most expensive house in area..when done (it sits on 2 big lots, one doesn't perk...7 acres maybe)

I ran into him today in old warehouse which we now rent back 1/2 of it. He told me of all the issues, he runs a restoration business, best I can he's doing OK, but the rest of work he has to SUB OUT.

He sounded VERY frustrated, he CANNOT GET BANK LOAN TO FINISH HOME....he must pay as he goes out of pocket....."because of what happened with the banks, they won't lend..." he added.

I'll say it again, the stock market rally (and it may have further and longer to go than most imagine or think reasonable) is built on gov and fed manipulation IMHO and the failed policies that are not growing economy are enriching the top 10% and BANKSTERS.

Sales of new homes sit at a generational low.....all that after TRILLIONS given away, GOV stimulus and incentives....lowest cost of home ownership in decades....housing the #1 FUEL for economy.....carpet....applainces, glass, blacktop, wood products, + jobs.

There may be a level of business we have fallen to, not one we are growing to which will bring us our of this morass.

FAILED policies continue, MINISCULE jobs bill will do little but make politicians look like they're doing something.

When you saw the INSANE action during internut bubble boom....companies did open, buy computers, rent space and hire people.

Housing bubble BOOM companies built things, people bought homes and stuff, companies rented space added employees....home equity loans added $1 TRILLION spending to economy...it was false yet real.

BOTH times the BOOM?BUBBLE was created by FED policies first with ASSHOLE GREENSPAN now bad bald buffoon BERNANKE....and the end result was ugly...then uglier....and we keep getting less bang for buck.

Bank branches are quiet, the door doesn't even swing open much on FRIDAY, PAY DAY....banks wont ledn, people dont borrow.....FED pays on excess reserves....cycle will continue.

WHAT HAPPENS good when MANIPULATION and interference with FREE MARKETS (WTF IS THAT?) attract capital in a one side one way overbalanced way?

Stay thirtsy my friends for the truth, do not take everything at face value....just like the other 2 mirages in last 10 years (WAY TO GO!!!) without coherent and free market policies that don't just benefit the connected few.....#3 being built as we speak.

I HOPE I AM WRONG, the more I talk to the man on the street the less hope I have.

D

GREENSPAN'S CONVIENENT MEMORY

BARRY RITHOLZ BLOG

WEAK AS A KITTEN

3 out of the last 5 UP days on Dow found up volume BELOW 50%, suggesting very weak demand. Todays advance saw a mere 31% UP volume....very selective purchasing of stocks.....now all this happening folks when Dow Theory 50% principal was in play...and bettered (passed 50% of losses from high to lows) and NEW HIGHS for move appeared.

If long, well you could say who cares, IMHO NONE of this smells like bull market action....but what do you call a 1 yr plus advance? A primary advance....inside of a SECULAR BEAR

SECULAR BEAR to me means over an extended period of time the stock market is poised to dissapoint, and buying at current levels may be even more so dissapointing....

FRI is OPTIONS EXP DAY....so it may be setting up to hold most of the gains into this period...a 31% up volume day and Dow gains 40 points.....how do you think that is accomplished?

NO WONDER people have left the party and dont give a hoot anymore...

D

IN A WORLD OF CRAZY

Nothing adds up, in 2002 the FED 1% rate policy fueled a sustainable recovery and the market exploded to new alltime highs. Autos hit records, sales and construction of homes, condos hit records....

We got the recession that wasn't many called after 911. But those in theknow, those supposed to be watching looked away and or fell asleep....and allowed aided and abetted the debt bubble housing crisis.

IN an interview in 2007 I believe BIG BEN BERNANKE was asked the question, "will housing slowdown hurt economy" he said "NO, and there has never been a case where home prices fell...." or something like that.....thank goodness they gave that bald bastard another term.

Paying interest on excess banking reserves STUNTS bank loans...that's a sure thing, but that policy continues.

BANK LOANS are contracting, now here me please THERE HAS NEVER BEEN A CASE IN HSITORY WHERE WE GOT A NEW BULL MARKET AND ECONOMIC EXPANSION AND LOANS OUTSTANDING CONTRACTED!!!

or A RECOVERY CALLED A RECOVERY WHERE WE SHED ANOTHER 1 million jobs!!!! SOME RECOVERY.

WE GOT THE RECOVERY IN BULLSHIT. There's no inflation to speak of because all those dollars are not getting into economy.....lead a horse to water....

Never has there been a disconnect like this one from sound findamentals and the stock market.

The stock market is rising for "some" good reasons, valuations on many companies paying dividends in 2009 were appealing, but please show me the companies right now selling for a low PE or low valuations....the bargains have gone.

If you are long, and the rally can carry much longer and higher than anyone anticipates, but IMHO it is rising not from a REAL improvment of life on the street, it is directly from FED and GOV interference......and as you can tell from the employment figures and remeber in those figures NOW I think are the HUGE hiring of temps for census....anf they still dont look good,

THEY have made it you can't get YIELD without taking some risk as ONE YEAR CD's YIELD maybe 1% whoopie......remember this next time it falls to shit and remember what tricks can be pulled....but also remember they cannot keep it up forever....let that punch bowl come away too soon....see what happens.

SHOULD A REAL AND LASTING RECOVERY NOT BE BORN HERE.....
you tell me what faith will be left in the system?

THEY BAILED OUT THE BANKSTERS with OUR money......and they still getting big money....even the thieves......and you telling me not even ONE SINGLE ARREST??????

WAY to go OBAMA for bringing us real change we can beleiev in...

D

BPSPX NOT CONFIRMING NEW HIGHS

Divergences at tops and bottoms usually show up. In a world of crazy, hard to predict anything

D

US HOUSING STARTS> WHERE'S THE BEEF?

1960 2010

THE DISTORTED TRUTH

The Dow has gained over 4,000 points from its lows of March 2009, during this time businesses shed an additional 1 million plus jobs, the 30 day up and down volume has been in declining trend since it made its high in April of 2009 only 1 month after lows.....both UNHEARD of for a "new bull market".

What good is government data like GDP if a rise in health care COSTS attributes to some of its rise? or inventory rebuilding? 5.9% GDP was a sham distorting actual productive job producing GDP.

Never before have we seen CONTRACTING BANK LOANS AND CREDIT OUTSTANDING leading to economic revival....going all the way back to the Great Depression.

Truths:

SPX companies are raising their dividends and buying back stock and are sitting on a HORDE OF CASH NEAR $900 BILLION.

Fact: Buying back stock supports the price, which enriches mostly the insiders who hold JOBS of it and are paid bonuses based on STOCK PERFORMANCE....the HORDE OF CASH is being used to buy up other companies...but then economies of scale lead to layoffs.....the HORDE OF CASH is not mostly going into productive means, job producing means which would be investment in plant and equipment....basically are we really going to revive our manufacturing sector and return those good paying jobs?

S & P 500 dividend yield is 1.94% one of the LOWEST payouts in HISTORY....bubble market tops have seen a low 3% yield where secular BEAR BOTTOMS have been associated with near 6% yields and SINGLE DIGIT SPX PE RATIOS.

MAJORITY of the stimulus is behind us, the FED is near end of quantitative easing (so they say) and the FED GOV is near $14 TRILLION in debt....

HOME is where most Americans count their wealth, which have lost SUBSTANTIAL value and almost all ability to support HELOC'S of which support increased spending...wages have been sickly stagnant for years.

GOV policy has made US companies healthier, cash horde, but money is not being spent that create jobs.....FED policy has bailed out the BANKING SYSTEM but they won't lend, and FED POLICY makes it more attractive to let excess banking reserves SIT IN THE DIGITAL VAULT because the FED is paying (printing) them to do so.....stricter lending standards, no incentive to lend, less demand for loans are Consumer in general are paying down debt mostly by DEFAULTS and they are 70% of our economy....

....IS THE GROUNDWORK the BASE built thru FED and GOV policy to lead us into a new sustainable expanding recovery? SO FAR there is NO proof that is ocurring. FACT

In SUndays 60 MINUTES report, it showed how the banks packaged the liar loans, the crummy mortgage paper of sub prime slime that's like the old $50 bill on top of a stack of $1's....and scammed the world.

It reported that GS went to AIG and got them to INSURE their pile of $12BILLION (knowing it was for shit??!!!) then AIG did a lot more....and when the market BUBBLE POPPED....they went DOWN>

WIth an AIG bailout....guess where $12 B was sent? to GS !!!!!!! KNOWING the paper was shit as reported by 60 MINUTES and Matt Taiibi ealrier, GS SHORTED THE CRAP OUT OF IT and made BILLIONS that way....if they knew it was for shit, was there not a crime committed here?

NOT ONE SINGLE BASTARD has been made to pay, not ONE SINGLE RATINGS AGENCY who must have known AAA was not warranted but needed to sell the shit paper....not one anybody has been prosecuted for any crime related to the biggest scam in history which has led to 8 MILLION jobs being lost in our economy.

Better yet, lets pay them BILLIONS to help clean it up....who would know better than the thieves who set it up? insult to injury on the American people...who got the bill.

JOB CREATION? yeah temp Census jobs...whoopie.

Now stories of educated workers being out of work 1 and 2 years and cannot find jobs paying HALF their former pay are just common place.

HAIL to the CHIEFS......and the historic rise in the stock market for the top 10%

Duratek

SPX 1980- PRESENT MONTHLY CHART

Understandable after 20-30 years of always HIGHER prices.....2000-2010 performance is not understood by the masses.

Possibly a first, at least for now most lemmings have not run after the market, MOST peculiar...pardon me, but the dumb money usually gets sacked.

Will a continued relentless rally FINALLY lure them in? then you know what happens next.....having that CRASH occur 2 X in 10 years may have chased many away from stocks for their lifetime....but savers are punished by FED policy. There is NO other game in town...my goodness it is MHO this is setting up to hurt a lot of people....

It's traders market for now, has been for 10 years, not a BUY AND HOLD. EXTREME oversold as I circled in my chart especially on monthly basis is usually a good risk to begin some longs should you have cash...like in 2009

That also requires you not pay attention to the news, just understanding that FED policy and worldwide central banks were pumping and backstopping like never before in history....once rallu got going it gained momo and had tons of doubters....and shorts to cover to feed it this past 12 months.

Some suggest it is early, all I will argue is prior 2 X FED stepped in and this time in an HISTORIC FASHION.....the KINDLING to the real world economy is no there like it was in 2002.

We also have had almost 30 years of BOND rally...if that isn't SECULAR what is? it's on its last legs.....higher rates...well that wouldnt be good.

Duratek

SHAM RECOVERY

WORTH THE READ link here

Market continued higher today, Dow closed at new recovery high.....

D

ENGINEERED COUP

Our bought off representatives.....story link

WILL STOCKS OUTPERFORM NEXT 10 YEARS?

Cresmont Research chart based on work by Shiller

Daily Reckoning when do Secular Bear Markets end? SPX dividend yield is below 2%.

HOW TO spot a bottom? Monevator.com

CLICHE'.....but more than not true:

The Bottom Line
"The old market cliché of being fearful when others are greedy, and greedy when others are fearful, proved to be especially true last March 2009, which was arguably the bottom of the bear market. While most investors ran for the sidelines, those that acted rationally and did research were amply rewarded. (Value investing may seem fool-proof, but it carries more risk than you might know. For further reading, see Buy High, Sell Much Higher.) "

Fear has been replaced by wild bullish sentiment and action, and technical indicators do not sniff out a top, selling desire has dropped rapidly......with near 0 yield on SAFE stashes.....money is flowing to a place it can get return.....for now...paper assets.

Wouldn't it be nice to see the return to a long term sustainable recovery where increased investment and job creation could revive spending and wage growth?

I don't see that. I see a stimulus driven market, backed by he FED policies, that each of the last 2 X's they did this it ended in disaster....3rd time a charm?

D

WELL WELL WELL

Deep subject. 4X prior since OCT of 2009 my indicator functioned well, until today. 4 out of 5 is pretty good, and shows why you use stops and don't bet the farm....in hindsight, betting against market going into a FED meeting.....probably not good idea.

MY observations have me thinking majority of times, market will reverse action from DAY OF FED meeting....ST market is well past due correction of at least 2-3%, maybe no more.

Holding SPX 1150 would logically lead to next level of R....maybe 1200-1250......leave hat at the door....opinions don't matter.

ODDLY....the little guy is staying put in mostly bonds and CASH best sources I can tell....meaning not buying into the greatest rally in history....burned too many times.

The perception of improving economy from where I sit, is of little solace.....a rise from the depths we sunk to even if appreciable is still FAR below what is needed to put people back to work.....and FAR from where we fell....

I won't say it's not improving.....but the BOOM this time instead of car buying, home equity withdrawls, housing speculation and boom bubble....we got ASSET inflation, bank credit contracting....deflation, inflation commodities, energy......soaring gov deficits and liabilities.....we have banks not stating earnings and liabilites accurately to reflect market conditions....condoned by gov...and it saved them and lured in investors even if the numbers don't add up.

M and A activity heating up.... many weak kittens getting eaten.

Not many bears left at all......guess that's OK. BOND YIELDS ACTUALLY FELL TODAY!!!

Bond market acts like we blew up and we're all dead. WHEN this party is over IMHO...ugly will have a new name.

Duratek

BIG FAT DEAL

Back in the Spring of 2009 or just before in the March time frame, the gov stooges got FASB to over rule their long standing accounting rule of marking assets to MARKET VALUE, what anyone is willing to pay for something at the current time, not yesterday,not tomorrow, but today.

But paying the pipe was not something they could stomach, so they basically FORCED GAO to change the rule and that began MARK TO MODEL (fiction) as property values have continued to decline over the past year.

BUT the financials have recovered, in most part because they now APPEAR sound....but are they?

Further, the FED 0% policy adds insult to injury basically PAYING HE BANKS NOT TO LEND.

Rally was born on manipulation and deceit, or outright fraud.....but surely we're all better off.

D

AM DATA

Housing starts at 8:30 then FED decision oooohhhh at 2:15.

Market action IMHO still suggests chances of near term pullback, heavy volume and little upside at resistance SPX 1150 suggest this is possible.

Longer term uptrend intact...TA wise.

D

FED INDECISION TIME

BOY, on pins and needles WHAT WILL THE FED DO???? nothing is the answer a big fat nothing

SURE it's gonna break one way or another here at 1150....I still think at least 2-3% correction is most likely....so treading water may be what you get until 2:15 on WED>

Boy, it seems to me, investors have little choice in where to go, and when doing it themselves, will not use tools the traders use....they are LONG HERE.

Experts are all LTBH so they got sick of riding the mkts down....try to do it themselves. A customer just left and he had over 50 stocks in pension portfolio.....which I thought was crazy

D

"WAITING" INDIGENOUS

We're all waiting for the truth, until our GOV comes cleans, until REAL changes come to Wall Street, us on main street left holding our ankles as our wealth and liberties get raped by those in charge to protect us....as long as the fox is left in henhouse...

Duratek

THINGS WE DO

"without music , there is no life"

Duratek

INDIGENOUS WITH CHRIS DUARTE

INSIDE WALL STREET COLLAPSE

LINK TO 60 MINUTES LEAD STORY SUNDAY IF YOU MISSED IT A MUST WATCH

Not only did those who created this disaster NOT PAY.....they are being paid to help clean it up!!

One guy figured the sub prime mess out, he made $725 M on the play, but the entire staff of rating agencies could not?

Fair playing field my ASS!

D

HOW LONG WILL RATES STAY AT RECORD LOWS?

FED MEETING THIS WEEK



ANY change IMHO might kill rally, but not usual for new highs surging, advance decline line new highs signalling ANY kind of imminent major top.



I put up the charts of the 2000 and 2007 tops so you could see they dont always form alike. 2000-2001 had some WILD swings before finally taking a nose dive to the 2002 lows.



AFter over 20 years of a major advance 1980-2000 or one could argue top of SECULAR BULL was 2007....is usally followed by 10-120 equal lean years.



2002 lows were violated so IMHO the NEW low gets tested...someday.



D

OLD SHELL GAME

MORE WORTHLESS PAPER

DON'T BE AFRAID TO BELIEVE IN THE RECOVERY

YIELDS ARE RISING BUT BOND BULL LIVES

When they break and hold OUT of this channel, most likely going to be very ugly

D

2007 TOP FORMATION AND BEAR MARKET

2000-2002 BEAR

MY WEEKLY DOW CHART

Until my moving averages cross....bull alive....and we are right at R line from 2007 I drew....yet we do have MACD cross.....whipsaw maybe.

YOU DECIDE

Duratek

ADVANCE DECLINE

ADVANCE DECLINE line have been making new rally highs, main street misery does not have to equal Wall Street misery, and there are not too many times in 100 years of market history that point to this data and a market top.

Upside to the rally with the FED liquidity machine not in reverse gives market a backstop....and more than one source says we are in the EARLY STAGES OF THE ADVANCE.....

What do you think? I have said I do not see a top forming using the TA I am accustomed to rely on, I was looking for near term weakness.

I am bearish on the ultimate outcome and resolution, but with cash yielding 0%......I understand the BULLISH argument......things going to be different this time?

You play the ODDS... I am NOT looking for a crash this year.....I am not looking for historic gains....maybe consolidation......

Is an accident lurking? well...action translates into technical picture and that's what we will go on and I will continue to update......

Duratek

IN YOUR FACE DUNK

WHY DID THE MARKET RALLY?

will the theories never cease? haaa

"The simple fact of the matter is that there it is, right in front of you.

A raw admission that the banks are carrying these loans at dramatically above their actual value.

Yes, this means that essentially all balance sheets must now be considered fraudulent, and thus the valuations assigned by the market to them are also fraudulent.

Extending this to the stock market as a whole you now have a market that is intentionally overvalued as a direct and proximate consequence of fraud, permitted and endorsed by the government, of somewhere between 25-40% "

BOND WATCH

DEBT REPUDIATION

Zero Hedge. Com What we don't need now is a BOND BUBBLE BURSTING

THE UGLY TRUTH

DO YOU SEE as far back as this FED chart goes , another time in history when BANK CREDIT was CONTRACTING???? IT IS as simple as THIS!! economies grow on expanding bank credit, the numnuts can come here and post all they want on this market going to moon etc, I am only trying to reveal what is behind the curtain. I am not sidetracked by market performance from my right to inform and share my opinion...to warn that the market is rigged and something is horribly wrong STILL!

Not even back to WORST it was after 911 after 2 years of FED easing and goosing and record bailouts etc etc and 70% mkt rise!!

The STock Market As Propaganda *if you missed this read it now.

DEAD CAT BOUNCE or EVERYONE LOSES *(back space to come back to blog)

CONSUMERS ARE THE ECONOMY: briefing.com

"The preliminary reading of the University of Michigan Consumer Sentiment Index slipped from 73.6 in February to 72.5 in March. The consensus expected the index to increase to 74.0.

In a somewhat surprising move, the current economic conditions index fell from 81.8 to 80.8. This was the first downward move in the index since November. Given the growing strength in the labor market, it was expected that the index would at least maintain its previous level."

FAILED BANK LIST

GREAT HOAX OF 2008??!! @ludwig von mises


"The beauty of the Great Hoax of 2008, from the perspective of the ruling class, is that is was also a Great Scare, and such scares invariably serve as pretexts for the rulers' most audacious assaults on the peasants' lives, liberties, and purses..."

from FED WEB SITE NOV 2009

.."Of particular concern, almost $500 billion of CRE loans will mature during each of the next few years. In addition to losses caused by declining property cash flows and deteriorating conditions for construction loans, losses will also be boosted by the depreciating collateral value underlying those maturing loans. The losses will place continued pressure on banks' earnings, especially those of smaller regional and community banks that have high concentrations of CRE loans.

The current fundamental weakness in CRE markets is exacerbated by the fact that the CMBS market, which previously had financed about 30 percent of originations and completed construction projects, has remained closed since the start of the crisis. Delinquencies of mortgages backing CMBS have increased markedly in recent months. "

Annecdote:

MY bank is now keeping track in a journal of branch foot traffic, because it has slowed to such an extent. If you desire a LOAN, you go into branch...that appears to have gotten WORSE so much so they have to track on daily basis.

The stock market is manipulated, the avg Joe is not benefitting, the banksters are....by not lending....what a beautiful system.

Duratek

REVERSE HEAD AND SHOULDERS IN YIELDS?

GROWTH OF M BASE DURING CRISIS

We will no longer monitor BDI as new ships enterring fleet "could" skew results.

D

BACK TO SPX 1150

NEXT UPLEG would be supported here on close and 2-3 day hold above IMHO.

MARKET WRAP DOW 15M VIEW

The American Consumer loves to shop and spend, maybe not as much lately and 8 MILLION unemployed, but those with money and jobs are doing what they can and our economy has pulled itself out from the abyss.

A STRONG market advance is very possible from here with many continuing to doubt it possible.

Nothing trades in straight line and out there are things we cannot know. ENOUGH has not been done and small business needs help and access to loans.

BY Bear MKT standards an SPX dividend yield at 2% is not even close to any previous Secular Bear bottom....DO WE make our way to a day when the SPX yields 6%? should that happen the SPX would be valued at 400....that sounds rediculous right?

But hasn't PRINTED money, FED back stopping been holding things together? Is there a limit? Does this come with a cost attached? inflation?

I don't see any technical issues yet....but this is anything but typical by any measure.

**closing notes

Today's rally was on a 14% drop in NYSE Volume. (sorry to bring that up again) The % of stocks above their 10-DMA continued its downtrend and suggests their isnt a lot of conviction at these prices. PNRA at $80 anyone?

D

BACK DOOR TAX INCREASES COMING

FORTUNE MAGAZINE LINK

"Since its conception, the Medicare tax has always been tied to payrolls. Every paycheck, employers and employees each chip in 1.45%, regardless of how much someone makes. Under Obama's proposal -- which should be very close to what Congress winds up enacting -- a Medicare tax would now be applied to investment income too: Individuals who earn more than $200,000 and couples over $250,000 would pay an additional 2.9% surtax on unearned income from interest, dividends, annuities, royalties and rents."

AM DATA

4 week moving average rose 5,000 to 475,000. AT the WORST it ever was in 2000-2002 bear recession peaked at about 500,000. It doesn't take a genius to see here something is wrong, is different in this recession and supposed recovery.....yeah I guess the Recession has already ended as they say....with MANY measures of Consumer Sentiment in a COnsumer led economy at near record LOWS, bank lending contracting and over 8 MILLION jobs lost....incl over ONE MILLION since March lows...a bull first I think.

D

IYR MONTHLY

IYR WEEKLY

IYR DAILY

SRS 30 M

IYR 30 M

MOMENTUM

GREAT SITE FOR THAT AND POTENTIAL STOCK CANDIDATES BASED ON THEIR PERFORMANCE

I am going to add some LONGS against my hedges.

Dow was laggard and small and mids were outperformers, underlying strength was masked as 2-1 advancers otherwise.

I can say my most trusted sources of stock market data have been pointing to a "melting away" of desire to SELL and certain measures of buying have been riding to new rally highs.....but because of the intensity of the selling that led to lows in March of 2009, dominant position belongs to selling....but in falling pattern....none of this unuaul in a cyclical bULL from Bear mkt lows....what is unusual was it took a year to overcome data highs that existed since the first month of the advance.

SPX dividend yield STILL SITS at what would be considered a BULL MKT TOP of a scant 2% YIELD.

Understand this, as we await unemplyment data this am, as things do get "less worse" around us, and employers are getting more reluctant to fire and less reluctant to hire.....it wont be enough to put the MILLIONS back to work, because between technology advances which make some workers obsolete, the other jobs have been shipped away.....do we focus more on little companies that can grow and multi nationals? or ones exposed or in CHina/ASia?....will China continue to grow at 8% and its middle class who would consume?

Have the banking woes been put behind us? or just swept under the rug? YIELD CURVE favors banking profits but NOT FROM LENDING....as bank credit a MAIN DRIVER to any economy continues to contract.

ABC COnsumer comfort poll languishes at record lows. RECORD GOV intervention and FED buying 80% of all mortgages not enough to propel housing....but we are near a bottom, but the bottom sucks....is the problems with CRE just hype from doom and gloomers?....of which are quickly evaporating as more and more become bulls.

VIX SUB 18 is not indicating much fear, and VERY LOW PUT CALL ratios indicate little protective positioning going on from traders fearing a back slide.

My charts I have been posting show we are at very important Resistance at many levels, and even if my bearish readers do not agree, you see less comments from them lately......the stock market is influenced by many different factors that are NOT connected to what the boots on the street see and FEEL.

TO ME.....it FEELS like being LONG is a NO LOSE DONT SWEAT IT DEAL......and many momo indicators bear the strength of move out.......anytime I see such one sidedness I watch my back......for the blind side.

a 70% MOVE while over 1 MILLION have lost jobs during......that may be one for record books and so has been FED response....it usually reaps stick advances.....and each time such dramatic action has been taken......well DO NOT FORGET 2002 and 2007 BEAR.....policies that run amuck and don't create a stable sustainable economic advance.....tend to END VERY BADLY.....as I am worried this one will too.

Maybe not until SPX 1200-1250......it needs to be clear to small business what gov policies are going to be and to what cost to them, before they begin to regain any confidence and hire like we need them to be.

Holding back hiring, building cash, holding off on investments.....could LEAD to an investment BOOM.....IMHO first.....the WEAK HANDS from March 2009 lows will be shook off before that ride ever takes place.

Duratek

MARKET AS PROPAGANDA

CHARLES HUGH SMITH

ONE CANARY 2?

TESTING THE WATER

Just a heads up. I am in 2 trades SRS @ $6.50 (stop $6.10)
and DXD $27.86 (stop $27.36)

Very ST in nature, I have added a component to my charting that looks promising so I am trying it out today to see how good it is at timing these trades.

I carenot what or in which direction the wind blows, just going to be looking for setups. These IMHO are decent risk considering current complacency, oversold nature and my new tools.

STops define my risk which I find acceptable. I'm NOT suggesting these for anyone, just going on record with my new tool, will advise on outcome.

D

THE REBUILD????

MORNING CHART

ANOTHER LOOK AND AT CROSSROADS

BANKING INDEX MAY BE KEY

SHORT TERM CALL

Using my MFI indicator, if past response is indiciative, the market appears to be tiring a bit, IMHO before an all out assault of 1150 SPX we are due for ST correction.

Duratek

GREAT DISCONNECT CONTINUES UNABATED

SMALL BIZ CRUNCH CONTINUES, NO NEED TO HIRE IF NO SALES

Sooner or LATER, the stock market is going to reflect the actual business climate, or one that may be around the corner.

FED Liquidity is the ONLY reason we are getting this historic levitation act, PLEASE understand it will end, and badly IMHO.....this is NOT to say new highs cannot be had....crazy as it sounds.

Only a drop back below 1120 might signal more ST problems. 1150 above opposite

D

SOBERING STAT

Chavon Sutton, staff reporter, On Tuesday March 9, 2010, 8:21 am EST

"The percentage of American workers with virtually no retirement savings grew for the third straight year, according to a survey released Tuesday.

The percentage of workers who said they have less than $10,000 in savings grew to 43% in 2010, from 39% in 2009, according to the Employee Benefit Research Institute's annual Retirement Confidence Survey. That excludes the value of primary homes and defined-benefit pension plans."

USING BULLISH % AS A TOOL

URANIUM ANYONE?

I've been waiting for the 10/25 cross but price has yet to recapture and move MA's into bullish position. There is the trendline I "could" use for a long trade as STOP LOSS if I was inclined to guess.

ANother chart somewhat befuddling was TAN the solar ETF, has it bottomed? why the weakness with the vocal support of alternative energy? more proof of trade what you SEE, not what you FEEL.

D

LONG TERM BUY AND HOLD STRATEGY

PAYS TO BE LONG TERM INVESTOR???????

Here's what DEFLATION can do, is this what we face now?

Take note our market is LOWER than 10 years ago.

Duratek

GOLD IN THEM THAR HILLS? OR CANARY?

what is this trying to say? or is it an OUTLIER to sector?????? or CANARY not in goldmine but to market????

KEY TO 1 YR OLD BULL MARKET?

BULL MKTS ACHILES HEEL? (IF this breaks and holds above 200 wk MA) not since 2007 just as SOME liquidity measures will ease......

A "fragile" recovery could be STOMPED OUT if rates get jiggy. My nephew was searching for home, found one for $215K, qualified for a 4.8% FHA LOAN!!!! unfortunately the $1,600 month was too much....as he could not put much down to lower loan amount.

Short sales from bank do not on avg make it to closing, because of the issues involving them.....there is a shitload of inventory out there and this all as incentives that really didnt work are running out....higher mortgage rates is something the PPT cannot allow.

Duratek

DECISION POINT TECHNICAL ANALYSIS

BULLISH VIEWS CARL SWENLIN

HOUSING PROBLEMS LINGER

"
Only the Shadow Knows: Housing experts say there's anywhere from 2 to 5 million homes ready to come on the market, due to pending foreclosure. In addition to this so-called shadow inventory, "I think people will become less resistant to defaulting on their mortgage," Shiller says. "That's a real cloud on the horizon."
-- Your Lender, Uncle Sam: The government has a hand in about 90% of all mortgages these days and Shiller is "not comfortable" with that level of involvement. The immediate problems, he says, are this spring's planned expiration of the first-time home-buyer tax credit and the Fed's mortgage-backed securities purchase program. "We can't just slam on the brakes and withdraw that -- we could but I'd hate to see what happens," he says. "When [government programs] do end there's going to be a psychological component of that ending as well, which is really hard to predict."

OUT OF BLUE, BOLT OF LIGHTNING

Back in OCT the 50 crossed the 200, it took awhile and then bamm, a huge gap is left below near $6, with HUGE volume this looks like blowoff move.

D

GUY LERNER

SOME INTERESTING CHARTS

Some more technical opinions

WILL JPM CHOKE ON IT?

Don't like the back drop? WHAT will happen if and when the FED ends its QE? that is what this enquiring mind wants to know.

IMHO, most investors are EXTREMELY comlpacent and looking at their statements seeing much of what was lost has been gained back and are not selling a thing.

Meanwhile the BOND market appears to be one of the MOST CROWDED plays in history

Duratek

MY WEEKLY SPX CHART AND COMMENTS