"Biggest step was the new TA now has the hardcopy files required."
Nah. That as just an excuse WDRP used, but it wasn't true.
Of the 42 penny stocks that used the same TA, only one other ever got a DTC chill (that was an obvious scam that is now under active SEC investigation following a ten day suspension).
None of the others were subject to a DTC chill, which is only ever imposed for specific serious reasons:
"Through its Office of Corporate and Regulatory Compliance (OCRC), DTCC monitors unusual large share deposits of microcap securities issues at DTC for signs of potential fraudulent behavior such as “pump and dump” schemes. This is when a small company’s stock price is “pumped up” by false press releases or chatter on the Internet and then insiders “dump” all their stock on unsuspecting investors when the price increases......
......if there’s an indication of fraudulent activity, it can place compliance “chills,” or processing restrictions, on the issue in question. It can also deny DTC eligibility to companies applying for DTC membership and services........
Mihal Nahari, DTCC’s chief compliance officer, noted that DTCC is careful to take action against microcaps only when there is a verifiable reason. In fact, DTC has placed chills on only 500 issues to date for compliance-related concerns, out of 3.6 million issues held at DTC. “Those 500 issues also represent less than 1% of the stocks worth under $1 in the depository,” Nahari said."
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