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BigBake1

03/26/14 4:15 PM

#62916 RE: integral #62913

My understanding is that a Deposit Chill is still applied when large deposits occur. The overnight courier service gives them time to act and respond within a reasonable period. If no response within 20 days... Hello Global Lock... You can forget ever seeing those shares again. The only time they will straight out issue a Global Lock now is if there is a Regulatory action from the SEC or FINRA.

So it is a stepped process, they are not getting pass from a Deposit Chill being applied, but they are not getting slapped with a Global Lock unless an action is filed or they ignore the Deposit Chill for 20 days. I find that a little more proactive than the past where a Deposit Chill can sit there for years without ever being addressed because they will just go to Scottsdale or Alpine for deposit of NON DTC securities.

The problem with Roger Pawson is... He doesn't use the same name, he has used multiple relative names in the past to get around being flagged as a repeat offender.
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janice shell

03/26/14 6:09 PM

#62931 RE: integral #62913

I understand "fair process" and "due process" under the spirit of the law. However, I fail to grasp the desire to provide Roger Pawson 20 days, as Roger and others like him are 99% of the time the issuer or related to the issuer.

DTC can still impose a chill or global lock on an emergency basis. In that case, the company has 20 days in which to appeal. It was the SEC who told DTC they had to be willing to interact with companies on this issue; hence the new proposed rule. And I agree that if you expect people--even crooks--to follow the rules, you have to tell them what the rules are.

The discussion isn't really about that. What BigBake and Brenda pointed out was that many companies with chills don't disclose that fact to their shareholders, which is misleading. If they don't do it, who will? We learned today that even TAs aren't necessarily informed.

So DTC is not considering BB's and Brenda's suggestion that it maintain a current list of chilled stocks at its website.