It's actually not THAT impossible. You just have companies at the sub dime range who do not care enough to comply with DTC regulations as 99% of the stocks below a penny aren't profitable in a way that allows for DTC compliance.
For instance, most OTC companies use 504s to register shares instead of the preferred S1 forms. Also, companies in the range being targetted have done a reverse split and immediately after have registered/issued more shares.
It's not a difficult or even impossible feat to become CNS cleared again, it's just companies either don't care or don't want to spend the cash to do it.
Also, not fully reporting companies are soon to be put on the list.
It really all comes down to whether or not the company wants to be compliant... soon the larger broker firms will follow suit with Penson and the list will grow, however, I believe a low percentage of those companies will come off the list - if they desire to keep trading.
So while I agree with part of your statement, there's still fault with it.
Either way, the changes (companies being added to the "T4T" list) are there to protect investors and larger brokers are actually clearing in house now or using smaller clearing houses so for now the sub-dime/penny stocks can stil lbe traded, but I think that will change soon as the DTC firms up the regulations.
Money (commissions) will be the deciding factor.
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