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BigBake1

04/07/14 12:05 PM

#1493 RE: Zardiw #1492

TDA is a good source to confirm DWAC/Deposit Chills, I often recommend checking with TDA when a chill is in question. AEMD had a CNS Exit Chill applied to it, which the DTCC stopped issuing in March 2012 due to the SEC requirement of a "Fair Process". Many of those old chills became DWAC/Deposit Chills and can be "lifted" using a process the DTCC has outlined.

Unfortunately the DTCC is not currently providing public notification of CHILLS, only Global Locks. I have been involved in current discussions over current DTCC proposals at the SEC website. I have recommended a public listing on the DTCC website concerning such service restrictions. The DTCC is reluctant at this point to do so, but has conceded it may provide public notices again for such chills.

The SEC has yet to rule on the proposal for approval and they amended the first proposal to include other requirements, one of which is notifying the Transfer Agent of such changes in DTC Services. Many assumed that TAs were in the loop, turns out they were not.

Looking at AEMD I can see they provided an SEC filing discussing the lifting of their chill and if TDA is allowing buying then the chill is no longer in place.