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fireopal

01/16/16 7:43 PM

#4633 RE: janice shell #4632

Disagree - KBIO trading was halted by Nasdaq and is quite different than being suspended, prohibited or terminated by SEC which is how i am interpreting that statement. Additionally, Finra clearly states broker/dealer only has to meet one element in order to be exempt from rule that applies to non-Nasdaq securities, and KBIO traded for 30 consecutive days before halt/delsting.

Rule 15c2-11 Exceptions

Question #17: Are there any exceptions from the informational requirements of Rule 15c2-11?
Answer: Yes. If a broker/dealer can meet one of the exceptions of Rule 15c2-11, it is not required to maintain or submit to the NASD any documents required by Rule 15c2-11. These exceptions primarily relate to instances where a broker/dealer wishes to quote a security that: is traded on a national securities exchange in the United States; represents unsolicited customer interest; has been the subject of regular and continuous quotations for the past 30 days; or is traded on Nasdaq.