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.