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Re: Alan Brochstein post# 72998

Tuesday, 07/22/2014 8:45:27 PM

Tuesday, July 22, 2014 8:45:27 PM

Post# of 221777
But don't you specialize in pot stocks? I realize there're a lot, but most of those suspended were among the most prominent.

I don't know the specific reason--or reasons--for the PHOT suspension, but my guess is that PHOT knows by now. It could have been the insider trading, but I'm inclined to doubt that, because it occurred just days before the suspension. The SEC rarely moves that fast unless what's going in is really outrageous, as with CYNK.

So, you think 30-day exclusivity is enough to compensate for the risks associated with filling out a Form 211?

It may be, in some cases. As you know, they can't accept compensation, and filing the Form 211 involved a fair amount of work. Some people--including MMs and Cromwell Coulson--would like for FINRA to change the rules so they could charge. I'm not sure how I feel about that.

FINRA has recently requested comment on its idea to start up a repository of Forms 211 filed. Among the questions they ask is whether companies should in some circumstances be required to update their documentation. Should that idea be adopted, I think perhaps the question of compensation for MMs should be revisited.

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