Mar. 4, 2025
My name is William Kelly a veteran of the U.S. Army and I've been a victim of what appears to me to be a crime. You may have heard of MMTLP, as American investors havent been quiet about the situation. In December of 2023, there was an open letter signed by over 70 members of congress to the SEC seeking answers for what occurred on December of 2022 with this stock. We have yet to receive answers or a resolution to this day, over 2 years after the incident. Please allow me to share some details about what transpired so you can be more informed about what exactly happened, and understand why I feel unfair treatment, and potentially criminal misconduct took place. There is alot of details surrounding the entire situation, but I will point out exactly where I believe regulatory authorities conspired against American Investors to outright steal our investment, and impede due process in the US stock market. On December 9, 2022, there was a U3 halt issued by FINRA, that not only halted trading of MMTLP, but prevented investors from selling the asset indefinitely, which begs the question of the "halt". This act conducted by FINRA, and allowed by the SEC, would have been legitimate, as they claim, if various sources including FINRA would not have misled and deceived investors regarding the last day of trading. This is the heart of where I believe criminal misconduct occurred. There seems to have been an intentional effort made to deceive investors committed by multiple organizations. The Vice president of the OTC Markets Group went on Trader TV live, clearly stating that the last day of trading would be on December 12, 2022, this proved to not be true, but this wasnt the only source to give the wrong "last day" of trading. Brokers informed their clients that the last day of trading would be Dec. 12th 2022. FINRA themselves in not just one, but two corporation actions for MMTLP clearly disclosed that the last day of trading would be on Dec.12th 2022, the last corporate action coming less than 24 hours before FINRA initiated a halt to indefinitely stop trading. Whether illegal activity took place, is yet to be determined, but there was definitely unfair and unjust treatment toward American Investors invested in MMTLP and a disregard for due process. FINRA broke their own policy and rules, specifically Rule 6490(d)(3),(4), and (5) when THEY wrote the company’s corporate action which created the settlement issue they used to justify the U3 HALT. According to the company CEO conducting the spin-off (George Palikaras), FINRA gave instructions to NOT alter anything in the corporate action. FINRA created the settlement issue, in their writing of the corporation action by using the wrong distribution date (which should have been December 14th 2022), which they then used as justification to HALT trading! The FINRA reasoning for the halt can be found in the FINRA F.A.Q. in regards to MMTLP published March, 16, 2023. This act, according to FINRA allowed 2.65 million short shares to enter a private company, but their lack of transparency and the fact 10 million shares were shorted on the day before (12/7/22) the halt, plus the fact FINRA admitted in the FAQ that they do NOT track shorted shares overseas, makes this 2.65 figure unreliable, and nothing more than a wild guess based on no real data, given that FINRA has refused to conduct a share count claiming an “undo burden”. FINRA references their authority to halt trading under rule 6440, but given the fact FINRA caused the “extraordinary event” in their writing of the company’s corporate action, makes this a gross abuse of their authority. MMTLP traded unauthorized, which violated FINRA rule 6432, and SEC Rule 15c2-11, by allowing it to trade without a Form 211, and with inaccurate company information submitted by some “unknown entity”, even though the company declared it at the merger to be a special dividend not meant to trade. The CEO disputed the trading, and attempted to stop trading, but FINRA and the SEC refused this request! All of this unscrupulous activity caused MMTLP to “hit Sam Dreddy’s fraud radar” on Dec. 5th 2022, 4 days before the halt, and in the FOIA request that disclosed this information, he also claims to be "pulling the bluesheets”, which FINRA later claims to be “a burden to obtain”. There are many more details surrounding the events of MMTLP that appear to show a coordinated effort to defraud investors by many different parties. I believe the fact FINRA broke multiple securities rules in their conduct with MMTLP warrants a serious investigation, and because of their conduct, they have also violated FINRA Rule 2010. The SEC has failed in their oversight duties under Gary Gensler to investigate this matter. Robert Cook has failed in his role at FINRA by allowing this blatant abuse of authority to transpire. There are a plethora of other details surrounding the MMTLP but this information essentially hits the heart of the matter. I hope this clearly conveys how I and many investors have been wronged. The resolution I seek is a complete independently audited share count of the TOTAL outstanding shares of MMTLP and the 2 days of trading that investors should have had, so all outstanding positions can be closed and settled. My funds have been frozen by this halt for over 2 years, and have affected my life in disastrous ways. I need your help in seeking answers from the SEC regarding their oversight of FINRA for breaking rule 6490, FINRA Rule 6432, SEC Rule 15c2-11, FINRA Rule 2010, and FINRA Rule 6440 which they used to issue the U3 Halt. I pray for a market based resolution for all investors still currently trapped in MMTLP. Thank you for your time and consideration in this matter.