and what if there ARE NO CHARGES against the company? What if the lock was placed there just to stop the illegal trading, which the company had no control over?
No notice to serve. Just lock it up and investigate. Then release and trade on my friends....
In this case, I guess, the appeal would be the simplest: that DTCC failed to notify the company of the charges. Which means that the suspension (legaly, a temporary action) was not meant to be long.
So, why then SGCP wouldn't simply appeal just right now? Because any appeal is expensive and take time and lawyers would just not go for such foolish thing. For the SEC would just shelve it: hold it without any action on it as long as they want and then just simply drop the lock, just as they would do without any appeal anyway.
The law presumes that in such temporry situations the time is of no essence for SGCP.