So, if an issuer requests a corporate action with FINRA before Jan 1, 2016, DTCC knows nothing about it until FINRA approves it. So, DTCC charges the fee if it hits their desk after the new year. That would make sense as some companies take months to get to DTCC stage of the process.
I know TAs have to send this form into FINRA directly before FINRA approves an action. This form actually can be sent in on the 9th day of the 10 day processes. But when does the TA actually contact DTCC is the question, and when does DTCC charge? Is that when they actually have to process it, not when they are informed that some day in the future an action will occur when approved by FINRA?
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