There may be an out in that the registration requirement applies for TAs of stocks that are either on a national exchange, or have more than 3M in assets and more than 500 stock holders of record.
CKYS doesn't meet the national exchange requirement, and I don't know whether or not it meets the second requirements.
National isn't registered with the SEC, and it isn't a bank. So, it could not operate as a TA for CKYS if CKYS meets either of the ablove requirements.
Have you ever tried reading SEC regs - THey are about as clear as liquid's posts on a bad day...