Once an issuer or its duly authorized representative submits a Company-Related Action
Notification Form, FINRA Operations will review the submission and may request
additional information or documentation as may be necessary to verify the accuracy of
the information. If the party that submits the form does not sufficiently respond within
90 calendar days of the date FINRA Operations requests additional information or
documentation, the request will be deemed “lapsed” and will be closed.

During the course of the review, if FINRA Operations believes that one of five explicitly
enumerated factors outlined in Rule 6490 may be triggered, it generally will conduct an
in-depth review of the Company-Related Action and may seek additional information
or documentation from the issuer or duly authorized representative as outlined above.
Where a Company-Related Action is deemed deficient, FINRA Operations may
determine that it is necessary for the protection of investors, the public interest and to
maintain fair and orderly markets, that documentation related to a Company-Related
Action will not be processed. Factors that may be considered by the FINRA Operations
in finding a request to process documentation related to a Company-Related Action
deficient are explicitly limited to the following:

1. FINRA staff reasonably believes the forms and all supporting documentation, in
whole or in part, may not be complete, accurate or with proper authority;

2. the issuer is not current in its reporting obligations, if applicable, to the SEC or
other regulatory authority;

3. FINRA has actual knowledge that parties related to the Company-Related Action
are the subject of pending, adjudicated or settled regulatory action or investigation
by a regulatory body, or civil or criminal action related to fraud or securities laws
violations4;

4. a government authority or regulator has provided information to FINRA, or FINRA
has actual knowledge, indicating that persons related to the Company-Related
Action may be potentially involved in fraudulent activities related to the securities
market and/or pose a threat to public investors; and/or

5. there is significant uncertainty in the settlement and clearance process for the
security.

6 Regulatory