Brilliant post and absolutely correct, the issue is not an Abusive NSS problem, the trading activity proves this, further it will show as stated in the coming FTD reports. Someone is eating a huge amount of rejected fees and this will all be disclosed through various reports including the 10Q covering this period, showing the conversion of restricted shares to free trading.
Simply put, someone jumped the gun and sold shares that had yet to be approved by the company and TA to be converted to free trading resulting in a block of rejected shares that could not be delivered until it was resolved.