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Re: Cassandra post# 125499

Tuesday, 05/20/2014 2:08:22 PM

Tuesday, May 20, 2014 2:08:22 PM

Post# of 148340
A complete NOBO list including all brokers for a specific record date can be ordered by an issuer (company) from Broadridge Financial Solutions, which is said to be "essentially the sole agent for intermediaries and companies."

Broadridge can produce a list of all NOBOs for a given record date in several different media formats, including paper copy, CD-ROM, and peel and stick labels. The record date of the request must be at least two or more business days in the future from the date you e-mail or fax your request. It will take an additional five business days from the record date for you to receive your list.

http://www.broadridge.com/corporate-issuer-solutions/shareholder-communications/shareholder/nobo-list-requests

Did PVEI (PVEC) submit an order for the NOBO list at least two to three business days in advance of the gift distribution record date? If not, how difficult is it to obtain a retroactive NOBO list?

More information on the NOBO/OBO distinction and related SEC rules:

http://www.kattenlaw.com/nobo

http://www.law360.com/articles/150005/making-sense-of-sec-s-nobo-obo-rules

http://www.sec.gov/comments/s7-14-10/s71410-22.pdf