There is nothing illegal about it, just like the DTCC can chill stock each self clearing brokerage can chill a stock. The SEC held a Roundtable discussion talking about these action on 17th October, 2011, they know all about it and support such actions to protect the market. It is pretty simple ATTD needs to stop using the Reg D 504 exemption as a blank check for financing it's operations and secure their own financing and take the same risk their shareholders are taking.