Very true. I think they will be significantly impacted. If anything, there will be a much smaller pool of tickers for them to go after, there could be some delinquent filers that slip though the cracks, or are not suspended right away, but they will have to worry about them getting suspended during the custodial process, and lose the $$$s, time and effort they have into it.....and they will no longer be able to rely on Form 15s to starve off suspensions.
As far as the suspensions taking a long time, it's possible....or....they could also suspended a massive amount of tickers, in a short amount of time...much like what happened in 'Operation Shell Expel' back in 2012, where hundreds of tickers were suspended in ONE DAY. Almost everyone who played shells back then got nailed. You have to assume the SEC making preparations for an 'Operation Shell Expel' Part 2, the hammer is going to fall, I'd almost guarantee it.
