I started contacting some SEC attorneys and did receive the following email back from one attorney that is recognized in this arena. Here is the email:

Ralph, after our phone call this week I started to ask around. My “sources” tell me that it all relates back to this FINRA Release in January:

http://www.finra.org/web/groups/industry/@ip/@reg/@notice/documents/notices/p117716.pdf

And that FINRA is putting the fear of God into clearing firms for failure to comply with this.

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