FINRA has a similar 10-day period before the Record Date
So one posibility is that they didn't try to bypass FINRA, but that they submitted the documents to FINRA (planning for the ex date to be the day after the Q3-report was due) and waited to issue a PR until FINRA had officially approved the distribution?
However, since they blame TRW my guess is that they indeed tried to bypass both exchanges.
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