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Wednesday, 11/16/2011 11:09:06 AM

Wednesday, November 16, 2011 11:09:06 AM

Post# of 213
Email response from NYSE:

FW: Universal Travel Group (UTA) - Trade halt update

FROM:

XXXXXXXXX

TO:

XXXXXXXXX

CC:

'jwu@christensenir.com'

Message flagged
Tuesday, November 15, 2011 4:27 PM




Your email has been forwarded to me for a response. I am afraid that we cannot comment to individual members of the public about regulatory matters relating to listed companies. However, I can provide you with some general guidance as to our policies and procedures with respect to trading halts.



The Exchange appreciates and is sympathetic to the difficult position in which shareholders of a listed company find themselves when trading in the company’s stock is halted, and is always committed to lifting any trading halt, if appropriate, as soon as possible to enable shareholders (and those holding a short position) to exit their investment if they so desire, or to initiate delisting if warranted. However, among a listing exchange’s primary regulatory obligations is to assure that in the absence of full and complete disclosure by a listed company, trading is halted to avoid any unfairness to all market participants. There is longstanding SEC legal precedent that an exchange must consider the interests of potential future buyers of a security ahead of the interests of existing investors. In the absence of full disclosure by a listed company, a listing exchange is obliged to halt trading to protect the interests of potential future buyers who might otherwise make an investment without all information required to be disclosed under the federal securities laws and exchange rules.



When trading in a company’s stock has been halted due to regulatory disclosure concerns, it is not possible to estimate how long it will take to either lift the trading halt or move to delist the company. The Exchange’s action is dependent on, among other things, how quickly the company responds to the Exchange’s information requests and how cooperative the company is in making the appropriate disclosures. In the course of its review and investigation, the Exchange may become aware of information that will lead to a conclusion that the company should be delisted on public interest or other grounds. The Exchange will only take delisting action after it has thoroughly considered all relevant facts and circumstances, so it is difficult to predict how long such action may take, as the Exchange’s experience varies widely with respect to how long it takes to gather all of the pertinent information and then analyze it.



It is important to note that listing is a voluntary decision by a public company. A listed company is always free to choose to voluntarily delist, which will generally open up trading on the pink sheets or OTCBB, subject only to the possibility of an SEC trading suspension. Moreover, under applicable SEC rules, listing exchanges are required to provide due process to any company subject to delisting, which includes the right to appeal to a committee appointed by the exchange’s board. Many companies avail of this appeal right which extends to the conclusion of the appeal process the period of time it takes to delist a company. In addition, any trading halt will continue pending the final outcome of that appeal. As noted above, if a company does not appeal a delisting action or voluntarily delists (if no action is pending), the trading halt will not be applicable once listing terminates.



Regards.



XXXXXXXXX





From: XXXXXXXXX
Sent: Tuesday, November 15, 2011 12:12 PM
To: NYSEDOTServices
Cc: jwu@christensenir.com
Subject: Universal Travel Group (UTA) - Trade halt update



Hi,

I am a shareholder in UTA:NYSE from Apr 12 2011, couple of days before UTA was halted from trading.



I would really appreciate if some information is shared with the shareholders about the status on this halt. UTA stocks were purchased especially because it is trading with one of the world's best stock exchanges, so it would be a great level of responsibility from the part NYSE to update the shareholders on any pending decision.



Thanks,

XXXXXX

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