FINRA doesn't have to approve a simple cash dividend. But the ex-date will be 1 day after the pay-date if it is more than 25% of the security value. Which could cause a lot of uncertainty and perhaps even a panic if people don't receive it after the record date. Once again.
But that is why you have me. Because I could see it coming 18 months ago and have been warning you about it ever since. If FINRA doesn't announce the ex-date before the record date then the company has to explain the procedure.