Should have known it was him.
Over another matter, I ended up having a conversation with the VP of legal affairs at Ameritrade. The NOBO lists came up seperately and he said Ameritrade was considering a blanket policy refusing to comply with any ADP requests where they suspected the company would be using the information for anything other than direct communications of a non-solicitive manner with shareholders.
He said that there was evidence some of these NOBO lists were winding up as public information and that Ameritrade could be considered liable for having released it. ADP has similar concerns, as they absolutely would be held liable for providing NOBO lists to company's for anything but their intended purpose.
I pressed him on who and why, pressed him for any information at all really, and he couldn't tell me anything more as it was an "active legal matter" at the moment, though I'm unsure what that means exactly.
I was wondering which one of these companies would be dumb enough to publish the NOBO list.