Don't forget to add the company to your list.
Yes, clearing firms are supposed to be gatekeepers. They're supposed to know what's going on, and if something doesn't seem right, they're supposed to report it. The same goes for transfer agents and company attorneys.
There're all kinds of things wrong with this story. The company's financials don't add up. The history of the only two notes CRGP disclosed is unclear, to say the very least. The status of the mines, if they even exist, is equally unclear.
The gatekeepers should have sensed potential problems, and done some work to find out what was really up. Same goes for FINRA. When it received that corporate action request, it should have wondered why the proposed dividend was so much higher than stock price. That should have led it to the financials, which, as noted, don't add up. It should have discovered that CRGP was issuing stock while buying stock back, and that should have raised more questions.
In sum, there were a great many red flags, but the people who should have picked up on them, didn't.
Market Data 
Markets 
