Strategic Management and Opportunity Corp (SMPP)

[Sully]

So on 2/28/11 FINRA rule 4320 applied to non-reporting companies.

From the rule:

http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p121916.pdf

Among other things, FINRA Rule 4320 requires participants of registered clearing agencies to take action on failures to deliver that exist for 13 consecutive settlement days in certain
non-reporting securities. In addition, if the fail to deliver position is not closed out in the requisite time period, a participant of a registered clearing agency or any brokerdealer
for which it clears transactions is prohibited from effecting further short sales in the particular specified security without borrowing, or entering into a bona fide arrangement to borrow, the security until the fail to deliver position is closed out.