I think if SEC settles and FINRA does not approve 211, FINRA would be embarrassed!!
The Market maker must apply to FINRA and agree to take spongy if the necessary paper work is in order and they are not in violations of any SEC/FINRA rules .. FINRA will grant the 211
PS. The Wells notice says that the SEC 'intends' to take action on a broad set of rules violation without specificity!!! And puts the onus on the respondent!!
The rules broken were published - have no doubt the company is going to be charged unless the company settles
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