I have reported to you regularly over the past 5 years relative to the roadblocks faced by small issuers in
obtaining DTC FAST eligibility, which has become a pre-requisite for major clearing brokers to accept shares for deposit and trading. In short, without DTC FAST eligibility, small issuers are left unable to trade; and their shareholders are left entirely illiquid. This has been the unfortunate result for hundreds of issuers who have been excluded from DTC FAST and is a major impediment to the SEC’s stated goal of achieving real dematerialization on an industry-wide basis as a precursor to moving from T+3 processing to T+2, now slated for 2017 or later.
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