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Thursday, March 29, 2012 11:32:00 PM
That's exactly what he did after the 2009/2010 dilution scheme in collaboration with Big Apple Consulting.
Of course the DTCC may take action in the meantime by removing IJJP from the NSCC Continuous Net Settlement System (CNS) or suspending all services but custody, which is known as a DTC Global Lock. Several of BAC's former clients have already met this fate for issuing unregistered Reg D 504 shares using an exemption they did not actually qualify for.
IMO Clifford Pope knows DTCC action is likely inevitable as he knows the exemption was bogus. He likely wants to sell as much as he can before the stock becomes illiquid.
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