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RareDealsHere Avatar Rare DD @RareDealsHere on x 3178 followers Created: 2025-07-18 19:12:10 UTC

Hi @SECPaulSAtkins,

Welcome to X!

By chance are you familiar with FINRA's September 16, 2015 U3 halt of ticker symbol $SWKH?

If I understand the story correctly, the issuer wasn't aware of FINRA's updated guidelines associated with their Rule 6490, so they basically tried to do too much, without first giving proper notice to FINRA, and therefore the investing public.

The good folks at FINRA acted swiftly!

On that very same day, they released a second UPC notice that not only informed investors that trading would resume the next day (September 17, 2015), but also that they were instructing all firms with trades executed in SWKH on September 16, 2015, to be cancelled, declaring them null and void in accordance with FINRA's Rule 11893.

So unless the fine people at FINRA have the memory capacity of goldfish, it would be laughable if they were ever to U3 halt trading in a security based on a hypothetical scenario where maybe a small number of brokerages might've misread a Corporate Action and neglected to prevent allowing clients to purchase a security that wouldn't have been settled in time for a record date...

All of this of course at the expense of the firms and investors that were prepared to participate in Position-Close Only transactions on the final two trading days as communicated to them by their respective brokerages.

I'm describing the final days of $MMTLP in case you haven't caught on!

Perhaps you should be in contact with George @palikaras, it's his birthday today.

Happy birthday George!

XXXXX engagements

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