The MMTLP Scandal: A Call for Accountability & Reform


The MMTLP Scandal: A Call for Accountability & Reform
The Issue
[UPDATE 3 - 2025 01 26] [(Letter to the President)]
To The Honorable Donald J. Trump, President of the United States,
Congratulations on your recent victory and inauguration. I hope this letter finds you in good health and high spirits. I write to you today not as your Commander-in-Chief’s loyal and dedicated U.S. Army Soldier, serving with pride for 27 years, but as a concerned citizen, family man, and investor with three young children. While I am deeply committed to serving my country in uniform, I am writing this letter in my personal capacity to bring to your attention a pressing issue that has left tens of thousands of American investors in financial and emotional distress: the unresolved crisis surrounding the December 9, 2022, trading halt and subsequent deletion of the Meta Materials Torchlight Preferred Shares (MMTLP) ticker.
These events, orchestrated by the Financial Industry Regulatory Authority (FINRA) and compounded by the inaction of the Securities and Exchange Commission (SEC) and the Depository Trust & Clearing Corporation (DTCC), have exposed significant vulnerabilities in our financial regulatory framework. Despite over 56,000 investor complaints and two congressional inquiries—led by Representative Ralph Norman (December 2023) and Representative Pete Sessions (June 2024)— there has been no meaningful response or action to address the systemic failings that led to the MMTLP crisis. Investors have been left in financial limbo, unable to reconcile their holdings or access their rightful assets, while regulatory bodies have remained silent.
The systemic issues extend beyond individual harm. This crisis has eroded public trust in U.S. financial markets and highlighted deficiencies in regulatory oversight. Synthetic shares, settlement discrepancies, and failures to deliver (FTDs) are just some of the unresolved issues that demand immediate attention. The affected investors are not only seeking justice for themselves but also advocating for the integrity of our markets and the restoration of faith in our regulatory institutions. As the leader of our nation, your support is vital in ensuring a resolution to this matter. I respectfully request your assistance in:
1. Urging Congress to hold a public hearing, akin to those held during the GameStop controversy, to investigate the systemic failures surrounding MMTLP and to provide a platform for affected investors to voice their concerns.
2. Supporting the enforcement of prior congressional inquiries and demanding accountability from FINRA, the SEC, and the DTCC.
3. Advocating for a Government Accountability Office (GAO) investigation into the regulatory lapses that have exacerbated this crisis.
4. Advocating for a Department of Justice (DOJ) investigation into potential criminal activities, including market manipulation and the creation of synthetic shares.
5. Encouraging legislative reforms to strengthen oversight mechanisms for self-regulatory organizations like FINRA.
This matter is more than a financial issue; it is a question of justice and the fundamental trust that underpins our democratic and economic systems. I am also in the process of disseminating an open letter to lawmakers, media outlets, and advocacy groups to build a broader coalition for action. I believe your voice and influence can be pivotal in accelerating efforts to resolve this crisis and restore public confidence in our markets. I understand that, as the leader of the free world, you have thousands of priorities competing for your attention. However, one phone call or email from your office could change the tide for 65,000 investors who have endured two years of being dismissed, ignored, and left to endure significant fiscal and emotional damage.
I have attached a copy of the executive summary for the open letter for your review. This letter is being sent to the senators of the U.S. Senate Committee on Finance through our respective elected senators and representatives from our home states.
I thank you for your time and consideration and remain hopeful for your support in this critical matter.
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[UPDATE 2 - 2025 01 24 [(X-SUM FINAL COPY)]
This executive summary is a pre-read provided to members of Congress in advance of the full petition and open letter, scheduled for release on or around February 1, 2025. It outlines the systemic regulatory failures surrounding the December 2022 MMTLP trading halt and deletion, highlighting the financial and systemic damage caused to tens of thousands of investors. This summary is intended to prepare lawmakers for the detailed requests in the full letter, which include Congressional oversight, GAO and DOJ investigations, and reforms to restore trust in U.S. financial markets is sent out Friday, 24 January 2025. This is the final version.
It reads as follows; the open letter itself is beyond the last update below.
TO: U.S. Senate Committee on Finance Members and Esteemed Lawmakers: Chairman Senator Mike Crapo (R-ID), Ranking Member Senator Ron Wyden (D-OR), and all member Senators; Chuck Grassley (R-IA), John Cornyn (R-TX), John Thune (R-SD), Tim Scott (R-SC), Bill Cassidy (R-LA), James Lankford (R-OK), Steve Daines (R-MT), Todd Young (R-IN), John Barrasso (R-WY), Ron Johnson (R-WI), Thom Tillis (R-NC), Marsha Blackburn (R-TN), Roger Marshall (R-KS), Maria Cantwell (D-WA), Michael Bennet (D-CO), Mark Warner (D-VA), Sheldon Whitehouse (D-RI), Maggie Hassan (D-NH), Catherine Cortez Masto (D-NV), Elizabeth Warren (D-MA), Bernie Sanders (I-VT), Tina Smith (D-MN), Ben Ray Luján (D-NM), Raphael Warnock (D-GA), and Peter Welch (D-VT).
THRU: Our Elected Representatives: Senator Andy Kim (D-NJ), Senator Cory Booker (D-NJ), Representative Josh Gottheimer (D-NJ), Senator Ashley Moody (R-FL), Senator Rick Scott (R-FL), Representative Maxwell Frost (D-FL), Senator John Cornyn (R-TX), Senator Ted Cruz (R-TX), Representative Lizzie Fletcher (D-TX), Representative Ralph Norman (R-SC), Representative Pete Sessions (R-TX).
FROM: SGM Daniel R. Auxier (NJ), Mr. Marcos Monteiro (FL), Mr. Brad Davis (TX)
DATE: January 24, 2025
SUBJECT: Executive Summary for Open Letter Addressing the December 9, 2022, MMTLP Trading Halt, December 13, 2022, Deletion, and Lack of Comprehensive Response to Congressional Inquiries from Representative Ralph Norman (R-SC) and Representative Pete Sessions (R-TX) (December 22, 2023, and June 5, 2024) by SEC and FINRA
1. Background. The open letter highlights FINRA’s issuance of a U3 trading halt without adequate explanation, followed by the deletion of the MMTLP ticker. These actions created systemic uncertainty, leaving investors unable to reconcile their holdings. Regulatory bodies, including FINRA, the SEC, and the DTCC, have failed to address issues such as synthetic shares, settlement discrepancies, and failures to deliver (FTDs), worsening investor harm. Despite the SEC’s awareness of these irregularities since 2021 and receiving over 56,000 emails and 848 complaints, 0.1% have received a response. This inaction violates the SEC’s mission to protect investors and maintain fair markets, highlighting the need for Congressional oversight.
2. Scope of Damage. The MMTLP trading halt and ticker deletion have caused extensive and deeply personal harm. Tens of thousands of investors have suffered significant financial losses, unable to access holdings or liquidate positions. Reports include suicides, fractured relationships, and a toxic environment within the X MMTLP community, marked by groupthink, cyberbullying, and harassment through doxxing and sharing of personal information. These behaviors have deepened the emotional toll, creating a climate of fear and distrust. Beyond individual harm, this crisis has eroded public confidence in U.S. financial markets, exposing systemic vulnerabilities that demand urgent attention. Immediate resolution is essential to support the affected community and restore trust in the regulatory system.
3. Purpose. This open letter addresses unresolved systemic failures stemming from the December 9, 2022, trading halt and December 13, 2022, deletion of MMTLP shares. These actions by FINRA, compounded by the SEC and DTCC’s prolonged inaction, have left tens of thousands of investors without resolution or recourse, undermining trust in the U.S. financial system. The letter draws attention to the original congressional inquiry led by Representative Ralph Norman (R-SC) and 74 co-signers on December 22, 2023, and a follow-up memo on June 5, 2024. Despite the significant time elapsed—over 400 days—no meaningful public action or accountability has followed, leaving investors in financial and legal limbo.
4. Request for Information. The letter requests detailed information regarding the decisions and actions taken by FINRA, the SEC, and the DTCC in relation to the December 9, 2022, U3 trading halt and subsequent deletion of the MMTLP ticker. Specifically, it seeks transparency on the rationale behind the halt, reconciliation of outstanding trades and synthetic shares, and efforts to address failures to deliver (FTDs). It also requests access to trading data (such as “Blue Sheets”), internal communications, and compliance documentation related to MMTLP and associated entities. Additionally, we would like to see any communications or information (redacted, if necessary) that Representative Norman and Congress have pursued to obtain answers and resolutions. Providing this evidence would demonstrate that this matter is being taken seriously, without requiring the submission of a FOIA request and the associated delays.
5. Request for Action. The letter urges Congress to take swift and decisive action to address the regulatory failures perpetuating the MMTLP crisis. It calls for a Government Accountability Office (GAO) investigation into the civil failings of FINRA, the SEC, and the DTCC, as well as a Department of Justice (DOJ) investigation into potential criminal activities, including market manipulation, synthetic share creation, and other violations. The letter also emphasizes the need for a forensic audit of MMTLP activity, the release of detailed trading data, and legislative reforms to strengthen oversight of self-regulatory organizations and improve protocols for extraordinary trading halts. Moreover, online activity on X must be investigated for evidence of influencers being paid by third parties to manipulate public narratives, intimidate individuals, or discourage participation in litigation and investigations. These tactics, such as doxxing—exposing confidential information to harass, bully, or silence—pose a serious threat to accountability. Finally, the letter requests a public hearing similar to the one held for GameStop and a formal meeting in Washington, D.C., with representatives and the SEC to directly address these critical issues with the open letter undersigned and petitioners present, if willing and able.
6. Conclusions. The MMTLP matter exemplifies systemic failings that demand immediate Congressional action. This open letter urges Congress to fulfill its oversight responsibilities, hold regulatory bodies accountable, and secure restitution for affected investors. The crisis has already spurred numerous lawsuits across multiple jurisdictions, exposing widespread harm and unresolved issues. As regulatory inaction persists, a third wave of legal filings is likely, signaling an escalating demand for justice and accountability. Additionally, online activity on X has been used by influencers, potentially paid by third parties, to manipulate narratives, intimidate individuals, and suppress shareholder collaboration through tactics such as doxxing. These actions further demonstrate the systemic nature of the crisis, which extends beyond two CEOs to include the actions and inactions of the transfer agent, broker-dealers, market makers, and regulators. All these elements must be thoroughly investigated to ensure accountability and systemic reform.
7. Notice. This executive summary serves as a read-ahead copy of the open letter, which is mailed and emailed to your respective offices no later than February 1, 2025. The open letter includes attached petition signatories and detailed supporting evidence. A full copy of the letter is also available for public viewing and download at www.change.org/resolveMMTLPnow
8. Open Letter. To ensure widespread awareness and total transparency, copies of the open letter are being shared with major news outlets, financial publications, investigative journalists, and relevant public platforms. The letter is also being disseminated to advocacy groups, legal professionals, regulatory experts, and the public online to foster a broader coalition for action. Its goal is to amplify the voices of affected investors, draw attention to systemic regulatory failures, and push for meaningful resolution and reform.
9. Acknowledgement. Please confirm receipt of the accompanying email and this attachment.
10. Point of Contact. For further questions, comments, or concerns, the undersigned can be contacted at (XXX) XXX-XXXX or XXXXXX@XXXX.com.
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[UPDATE 1 - 2025 01 17]
At the request of many, a TL;DR (too long, didn't read) of this open letter is as follows;
The open letter, addressed to Congress and regulatory bodies, details unresolved issues surrounding the December 2022 halt and deletion of the MMTLP ticker. It highlights:
1. Regulatory Failures: FINRA's indefinite trading halt and deletion of MMTLP shares without clear explanation, coupled with the SEC's inaction despite over 848 complaints, more than 56,000 emails submitted by concerned investors, and FOIA evidence of irregularities since 2021.
2. Investor Harm: Tens of thousands of investors have been left without recourse or clarity, eroding trust in financial markets. The SEC's lack of response and FINRA's failure to enforce rules exacerbated financial losses.
3. Systemic Issues: Evidence points to market manipulation, synthetic shares, and unresolved failures to deliver (FTDs). FINRA and the DTCC are criticized for inadequate oversight and accountability.
4. Legal and Constitutional Concerns: Actions by FINRA and the SEC are described as unconstitutional, denying due process and violating shareholder rights. Multiple lawsuits are cited, reflecting the scale of investor grievances.
5. Call to Action: The letter demands congressional hearings, a GAO investigation, DOJ intervention, and comprehensive reforms to address regulatory negligence, restore investor confidence, and prevent future crises.
Special Note: The document also includes minor criticism of former Torchlight Energy CEO John Brda and key figure Greg McCabe for not negoating positive results or resolving the situation. Additionally, Next Bridge Hydrocarbons (NBH) is called out for failing to respond to official shareholder requests for information, further compounding investor frustrations and leaving unresolved questions. Despite this information being 2.4% of the total documents text and objectively factual in nature, this note has been added based on others feedback. Please remember to read all of the document before signing. Thank you.
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[THE OPEN LETTER - 2025 01 15]
Distinguished Lawmakers and Esteemed Representatives,
We write this open letter to bring to your attention the unresolved and critical issues surrounding the trading halt and eventual deletion of the Meta Materials Torchlight Preferred Shares (MMTLP) ticker. On December 9, 2022, FINRA issued a U3 trading halt, freezing all trading activities without prior notice or adequate explanation. Just days later, on December 13, 2022, the MMTLP ticker was deleted, leaving tens of thousands of investors unable to access or reconcile their holdings. These events exemplify systemic regulatory failures, encompassing systemic manipulation, regulatory negligence, and breaches of fiduciary duty. The MMTLP case presents a monumental challenge to the trust and integrity of U.S. financial markets.
The issues arising from the MMTLP halt highlight a series of profound missteps and structural flaws. FINRA's actions, including the indefinite halt citing “extraordinary events” without substantive explanation, underscore the unchecked powers of self-regulatory organizations and the failure of oversight bodies like the SEC to intervene effectively. This lack of clarity and accountability has left investors in limbo for over two years, further eroding confidence in our financial system. As individuals deeply affected by this crisis, alongside tens of thousands of investors, we implore Congress and regulatory bodies to address this injustice with urgency and transparency.
The SEC was aware of potentially fraudulent activities affecting MMTLP as early as 2021, well before the December 9, 2022, trading halt and the subsequent deletion of the ticker on December 13, 2022. Despite receiving 848 formal complaints and over 56,000 emails from concerned investors—facts uncovered through Freedom of Information Act (FOIA) requests—the Commission has taken no meaningful steps to resolve the issue. To date, only 35 complaints have received an official response, representing a dismal 0.06% resolution rate. This negligence underscores the SEC's failure to fulfill its fundamental mandate to protect investors and maintain fair and transparent markets, even two years after the halt.
FINRA and DTCC are equally culpable, having failed to enforce existing regulations, address short positions, and resolve discrepancies in share reconciliation. These entities must be held accountable for their roles in exacerbating the harm to investors. Regulatory bodies cannot be allowed to operate without consequence when their actions—or lack thereof—directly undermine public trust and market integrity. Congress must demand a full accounting of their decisions and take steps to ensure these failures are not repeated.
The Financial Industry Regulatory Authority (FINRA) compounded the harm by failing to follow its own rules, including those governing the settlement of short positions. FINRA's Rule 504 requires the prompt close-out of short positions in specific circumstances, yet no such actions were taken to enforce compliance in the wake of the trading halt. This failure to enforce existing regulations has left investors with unresolved and increasingly detrimental financial positions. Moreover, FINRA's decision to issue an indefinite halt, citing vaguely defined “extraordinary events,” and its subsequent deletion of the MMTLP ticker without a clear and transparent process, reflect a lack of accountability and procedural fairness. These actions highlight systemic flaws in the governance and oversight of self-regulatory organizations.
The unprecedented actions taken by FINRA in relation to the MMTLP trading halt and subsequent deletion of the ticker reveal significant irregularities in the handling of this corporate action. According to evidence from the case file, the Uniform Practice Code (UPC) Committee played a central role in determining the halt, citing an “extraordinary event” as justification. However, the corporate action surrounding MMTLP was unique and anomalous, differing starkly from standard procedures. The decision to halt trading indefinitely and delete the ticker entirely deviated from established norms, as similar corporate actions have historically allowed for orderly resolution and settlement of positions. FINRA’s failure to provide a transparent explanation or follow standard practices raises serious concerns about the integrity and impartiality of the UPC Committee’s decision-making process. The lack of clarity surrounding this corporate action has left investors in financial limbo, compounding the perception of regulatory failure and eroding confidence in the fairness of market oversight.
The handling of the MMTLP case raises significant constitutional concerns, including the unlawful taking of private property without due process. By effectively erasing the value of MMTLP shares and denying investors access to their holdings, regulatory bodies and their subordinate self-regulatory organizations have engaged in an arbitrary and excessive exercise of power. Over the past three years, these entities have consistently demonstrated a lack of transparency, failed to provide substantive justifications for their actions, and denied affected investors their right to fair treatment under the law. This prolonged inaction and disregard for due process not only violate fundamental legal principles but also undermine public trust in the integrity of the financial system. It is imperative that Congress and regulatory agencies address these failings with urgency and transparency to restore confidence and ensure accountability.
The involvement of the Depository Trust & Clearing Corporation (DTCC) further complicates the MMTLP case, as its role in the settlement process underscores critical accountability gaps. As a central clearing organization responsible for ensuring the smooth transfer of securities, the DTCC failed to address unresolved failures to deliver (FTDs) and discrepancies in share reconciliation, exacerbating investor harm. This lack of oversight and enforcement highlights vulnerabilities in a system where key market participants operate without adequate checks, leaving investors with no recourse and deepening the financial and legal uncertainties caused by the halt.
The ongoing case, Davis v. Next Bridge Hydrocarbons, Inc. et al. (Case No. 3:24-cv-03058), alleges systemic issues that have compounded the MMTLP crisis. This case highlights significant failures by the Depository Trust & Clearing Corporation (DTCC) in managing settlement processes, resulting in gaps in accountability and transparency. It further exposes unresolved failures to deliver (FTDs) and discrepancies in the settlement process that have intensified investor harm. The lawsuit seeks to address these critical shortcomings and advocates for meaningful reforms to ensure fair and transparent market operations. The evidence points to a troubling pattern of systemic manipulation. Synthetic shares—created through improper trading practices—flooded the market, artificially inflating the share supply and suppressing prices. The trading volume for MMTLP far exceeded the authorized float of 165 million shares, suggesting the proliferation of counterfeit shares. FOIA-released documents reveal that both the SEC and FINRA were aware of these irregularities as early as November 2021 but failed to act decisively. This inaction allowed market manipulation to persist, eroding investor confidence and undermining market integrity.
The governance structure of FINRA adds another layer of complexity and concern. As a self-regulatory organization wielding quasi-governmental authority, FINRA’s unilateral actions, such as the U3 halt, lack the checks and balances typically applied to federal agencies. This governance model raises constitutional questions, particularly under the separation of powers doctrine. The lack of meaningful oversight over FINRA’s decisions has left investors with no recourse and exacerbated the harm caused by the halt.
The ongoing case, Auxier v. SEC (Case No. 7:24-CV-318), alleges systemic failures that have exacerbated the MMTLP crisis. This case exposes significant lapses in regulatory oversight, particularly by the Securities and Exchange Commission (SEC), in its failure to enforce compliance by the Financial Industry Regulatory Authority (FINRA) and the Depository Trust & Clearing Corporation (DTCC). It argues unresolved failures to prevent or address the proliferation of synthetic shares, which flooded the market, artificially inflated share supply, and suppressed prices. These manipulative practices created significant discrepancies in share ownership and left countless investors unable to reconcile their holdings.
The lawsuit further challenges the SEC’s inaction, despite documented evidence of fraudulent activities related to MMTLP as early as November 2021. Freedom of Information Act (FOIA) documents reveal that the SEC and FINRA were aware of these irregularities yet failed to take meaningful steps to investigate or resolve the issues. This inaction allowed synthetic shares and failures to deliver (FTDs) to persist unchecked, undermining investor confidence and market integrity.
The case also raises broader implications for market fairness and governance, particularly highlighting constitutional concerns regarding FINRA’s quasi-governmental authority and lack of oversight. By advocating for reforms, the lawsuit seeks to hold the SEC accountable for its failures and ensure greater transparency and accountability within regulatory bodies. Through these efforts, Auxier v. SEC aims to address systemic shortcomings and restore fairness to U.S. financial markets.
The scale of public outcry over MMTLP’s halt has been unprecedented. On December 22, 2023, Representative Ralph Norman led a bipartisan coalition of 74 members of Congress in a letter to the SEC and FINRA, demanding answers and accountability. Despite Congress receiving over 40,000 complaints from affected investors, there has been little progress or meaningful engagement from regulatory bodies. The lack of resolution not only damages the financial wellbeing of investors but also undermines public trust in regulatory institutions.
Additionally, corporate leadership, including figures such as John Brda and Greg McCabe, have failed to take meaningful action to address shareholder concerns. While McCabe continues to play a role in related enterprises, both he and other executives have yet to offer legal solutions or advocate effectively through lawmakers for investors trapped in this debacle. This absence of accountability among corporate officers further highlights the systemic issues plaguing the MMTLP case.
Adding to the frustration, Next Bridge Hydrocarbons has consistently failed to respond to shareholder concerns or provide substantive updates. Despite multiple formal requests for information and accountability, as shareholders, the company has avoided addressing critical issues related to share reconciliation and investor grievances. This lack of communication has compounded the distress faced by affected investors and underscores the broader failures of governance and transparency within this matter.
The lack of action from regulatory bodies, corporate leadership, and other financial market entities compounds the financial and emotional distress of MMTLP shareholders. Investors have remained trapped in a situation where neither governmental agencies nor corporate entities provide clear paths to resolution. For instance, despite multiple inquiries regarding share ownership discrepancies and the processes for transitioning assets, Next Bridge Hydrocarbons has offered no viable solutions. The systemic failures have left many investors feeling abandoned, further eroding their trust in the fairness of the U.S. financial system.
The widespread fallout from the MMTLP matter has led to a surge of legal actions across various jurisdictions, underscoring the systemic failures that have affected tens of thousands of investors. Among the notable cases is Pease v. SEC (No. 7:24-cv-00322-DC), filed in the U.S. District Court for the Western District of Texas, which highlights regulatory negligence by the SEC and its failure to act on fraudulent market activities. Similarly, Spears v. Next Bridge Hydrocarbons, Inc. (No. 7:24-cv-321), also in the Western District of Texas, focuses on corporate governance failures and the lack of accountability in resolving investor grievances tied to Next Bridge Hydrocarbons. The Vetrano v. Brda case (No. 7:24-cv-325) sheds light on alleged mismanagement by corporate officers, amplifying concerns about fiduciary responsibilities and shareholder protection. Additionally, SEC v. Brda reveals the regulatory agency’s focus on addressing specific allegations of misconduct related to corporate leadership, further illustrating the complex and pervasive nature of the crisis.
Additional cases further expose the pervasive nature of the crisis. Rolo v. SEC (No. 3:24-cv-02053), brought in the U.S. District Court for the District of Connecticut, challenges the SEC’s oversight and its failure to prevent or address market irregularities. Willcot v. SEC (No. MO:24-cv-317), filed in the Western District of Texas, similarly targets regulatory shortcomings, calling into question the efficacy of current oversight mechanisms. The Inter-Coastal Waterways LLC v. TradeStation Securities, Inc. (No. 0:24-cv-60891), in the U.S. District Court for the Southern District of Florida, highlights discrepancies in brokerage practices, particularly failures in reconciling investor accounts and enforcing market regulations.
Further emphasizing the national scope of this issue is Taggart v. Next Bridge Hydrocarbons, Inc. (No. 1:24-cv-01927), brought in the U.S. District Court for the Eastern District of New York. This case raises critical questions about the actions of corporate entities in the wake of the trading halt and ticker deletion. Traudt v. Rubenstein et al. (No. 2:24-cv-00782), filed in the U.S. District Court for the District of Vermont, delves into the systemic creation of synthetic shares and the impact of these practices on market integrity and investor confidence. Together, these cases paint a comprehensive picture of the legal challenges surrounding the MMTLP matter, demanding urgent action to address the structural flaws and systemic failures that have harmed investors across the country.
Finally, as mentioned above, the SEC v. Brda case pertains to actions involving Torchlight Energy Resources (TRCH), the predecessor to MMTLP, rather than MMTLP directly. Torchlight Energy Resources merged with Meta Materials Inc. (MMAT) in 2021, forming the backdrop for the issuance of MMTLP shares. During and after the merger, both TRCH and MMAT experienced unusual and anomalous stock activity. Despite this, the SEC's actions related to these issues have not produced any substantive results or public updates in over two years.
While the investigation into the alleged actions of John Brda and George Palikaris might suggest regulatory engagement, it falls far short of addressing the broader systemic issues at play. Targeting a few individuals as scapegoats does little to resolve the widespread failures of oversight and enforcement that allowed the MMTLP crisis to unfold. The focus on these individuals serves as a symbolic gesture rather than a meaningful effort to hold accountable the institutions, regulators, and market participants who enabled the proliferation of synthetic shares, market manipulation, and regulatory negligence. By concentrating on a narrow investigation, the SEC diverts attention from its own inaction and the larger systemic failures that continue to harm investors and undermine confidence in U.S. financial markets. A genuine effort to restore trust requires a comprehensive investigation into all actors and entities involved—not just the convenient targeting of a few.
Additionally, the SEC has acknowledged through official documents that an investigation is ongoing into actions and parties connected with MMTLP. Despite this investigation being active for approximately two years, no public results or updates have been released. Meanwhile, investors are left waiting for clarity and answers from the SEC. During this prolonged period of inaction, the statute of limitations may begin to toll, potentially stripping investors of their legal rights to file lawsuits against involved parties.
The handling of the MMTLP trading halt and subsequent deletion represents a stark violation of basic shareholder rights. Shareholders have a fundamental right to access timely and accurate information about their investments, participate in corporate decision-making, and seek redress in cases of suspected misconduct. In this case, the sudden U3 halt imposed by FINRA, followed by the deletion of the MMTLP ticker, denied investors the ability to react or even understand the reasons behind these actions. The lack of transparency, coupled with the absence of an adequate explanation, left shareholders without recourse and exacerbated financial harm, undermining the trust and confidence that are critical to functioning financial markets.
Compounding the harm is the prolonged inaction of the SEC, which has failed to provide any meaningful updates or results from its admitted ongoing investigation into MMTLP and related parties. Shareholders have waited for over two years, during which time critical statutes of limitations may begin to toll, effectively removing their ability to pursue legal remedies. This inaction denies shareholders their right to accountability and justice while regulatory agencies, which are tasked with protecting investors, fail to fulfill their mandates. These systemic failures demand immediate congressional oversight and action to restore fairness, transparency, and investor confidence in U.S. financial markets.
The need for action is clear and urgent. To address the systemic issues outlined in this memorandum, we recommend the following steps. Transparency must be prioritized. Detailed trading data, such as “Blue Sheets,” should be released to clarify the extent of trading irregularities and the proliferation of synthetic shares. Legislative reforms are needed to strengthen oversight mechanisms for self-regulatory organizations, ensuring their actions are subject to meaningful review and accountability. Protocols must be established to address extraordinary trading halts, with clear timelines and mandatory disclosures to affected parties. Finally, a comprehensive forensic audit of MMTLP trading records is essential to identify and rectify discrepancies and to restore investor confidence.
We formally request a Congressional Hearing akin to those held during the GameStop controversy, as the issues uncovered during that incident pale in comparison to the MMTLP fiasco. With over 65,000 investors affected, the scale and severity of the systemic failures surrounding MMTLP—including the proliferation of synthetic shares, regulatory negligence, and the deletion of the ticker—demand a thorough and public examination. A hearing is critical to understanding the root causes of these failures, holding accountable the parties responsible, and implementing the necessary reforms to ensure transparency, fairness, and confidence in U.S. financial markets.
It is imperative for Congress to exercise its oversight authority to address this regulatory breakdown. When agencies like the SEC and FINRA fail to protect investors and uphold market integrity, it is Congress's responsibility to intervene. By taking decisive action, you can reaffirm the accountability of these institutions and restore public confidence in the financial system.
We respectfully request that Congress initiate a Government Accountability Office (GAO) investigation into the practices and oversight mechanisms of FINRA, the Depository Trust & Clearing Corporation (DTCC), and the Securities and Exchange Commission (SEC). This investigation should examine systemic failures, including regulatory gaps, lack of accountability, and potential conflicts of interest that have exacerbated the MMTLP crisis.
We urge the Department of Justice (DOJ) to intervene and investigate possible violations of federal securities laws, including allegations of market manipulation, synthetic share creation, and failures to deliver (FTDs). These actions are essential to restoring public trust in our financial markets, holding responsible parties accountable, and preventing similar injustices in the future.
We, the undersigned, request a meeting in Washington, D.C., to discuss these issues with the SEC and our congressional representatives. This meeting, which should include our legal counsel and theirs, would provide an opportunity to address, and perhaps settle, any unresolved trading irregularities, explore compensation mechanisms for investors, and develop actionable plans for regulatory reforms. We believe such engagement is critical to achieving justice for MMTLP investors and to restoring trust in our financial system.
As we approach more than two years since the MMTLP trading halt, the absence of resolution continues to harm thousands of investors and casts a long shadow over the integrity of U.S. financial markets. This case offers Congress and regulatory agencies a unique opportunity to demonstrate their commitment to transparency, fairness, and accountability. By addressing the systemic failures that have defined the MMTLP matter, you can help rebuild public confidence in our markets and ensure that such injustices are not repeated.
We urge you to take immediate action to resolve this matter, provide restitution to affected investors, and implement the necessary reforms to safeguard market integrity. Together, we can ensure that our financial markets remain a cornerstone of fairness, transparency, and opportunity for all participants.
We have attached copies of the last two congressional memos regarding concerns for MMTLP for your records and review. These memos dated December 22, 2023, and June 5, 2024, highlight the breadth of concern among our lawmakers and the urgency of addressing the systemic issues surrounding MMTLP. To our knowledge, no public action has been taken in response to these memos, aside from a brief public exchange with SEC Chairman Gary Gensler. During this conversation, between Ralph Norman and Chairman Gensler, the chairman failed to provide any meaningful insights, solutions, or even an apology to the tens of thousands of investors affected by this ongoing crisis. This lack of response underscores the need for immediate and decisive action. The lack of comprehensive responses to congressional inquiries is deeply troubling and raises questions about the accountability mechanisms in place for regulatory agencies.
If it were me, or any other citizen or government employee standing before Congress, such a lack of transparency or accountability would likely have been met with far greater scrutiny and consequences. This disparity is not lost on the public, and I trust that you understand the frustration and sense of injustice it fosters. I respectfully urge you to recognize this imbalance and take meaningful steps to address it.
The SEC has had over three years to address and resolve the MMTLP fiasco, both before and after FINRA’s imposition of the U3 halt and subsequent deletion of the ticker. The Commission suffers from no shortage of knowledge, resources, authority, or funding—yet it has failed to fairly resolve what should be a straightforward matter: a preferred stock dividend from a relatively obscure oil and gas exploration company. This glaring inaction raises a critical question: if the SEC cannot competently address this relatively contained issue in a timely manner, how can it be expected to handle far larger market challenges or respond effectively to emerging financial contingencies? The inability to resolve this crisis undermines confidence not only in the SEC but also in the broader regulatory framework designed to protect investors and ensure market integrity.
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Please note: An official signed memorandum from the authors is sent to their respective congressional and gubernatorial offices, with this petition's signatories attached as a record of their endorsement of this open letter.

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The Issue
[UPDATE 3 - 2025 01 26] [(Letter to the President)]
To The Honorable Donald J. Trump, President of the United States,
Congratulations on your recent victory and inauguration. I hope this letter finds you in good health and high spirits. I write to you today not as your Commander-in-Chief’s loyal and dedicated U.S. Army Soldier, serving with pride for 27 years, but as a concerned citizen, family man, and investor with three young children. While I am deeply committed to serving my country in uniform, I am writing this letter in my personal capacity to bring to your attention a pressing issue that has left tens of thousands of American investors in financial and emotional distress: the unresolved crisis surrounding the December 9, 2022, trading halt and subsequent deletion of the Meta Materials Torchlight Preferred Shares (MMTLP) ticker.
These events, orchestrated by the Financial Industry Regulatory Authority (FINRA) and compounded by the inaction of the Securities and Exchange Commission (SEC) and the Depository Trust & Clearing Corporation (DTCC), have exposed significant vulnerabilities in our financial regulatory framework. Despite over 56,000 investor complaints and two congressional inquiries—led by Representative Ralph Norman (December 2023) and Representative Pete Sessions (June 2024)— there has been no meaningful response or action to address the systemic failings that led to the MMTLP crisis. Investors have been left in financial limbo, unable to reconcile their holdings or access their rightful assets, while regulatory bodies have remained silent.
The systemic issues extend beyond individual harm. This crisis has eroded public trust in U.S. financial markets and highlighted deficiencies in regulatory oversight. Synthetic shares, settlement discrepancies, and failures to deliver (FTDs) are just some of the unresolved issues that demand immediate attention. The affected investors are not only seeking justice for themselves but also advocating for the integrity of our markets and the restoration of faith in our regulatory institutions. As the leader of our nation, your support is vital in ensuring a resolution to this matter. I respectfully request your assistance in:
1. Urging Congress to hold a public hearing, akin to those held during the GameStop controversy, to investigate the systemic failures surrounding MMTLP and to provide a platform for affected investors to voice their concerns.
2. Supporting the enforcement of prior congressional inquiries and demanding accountability from FINRA, the SEC, and the DTCC.
3. Advocating for a Government Accountability Office (GAO) investigation into the regulatory lapses that have exacerbated this crisis.
4. Advocating for a Department of Justice (DOJ) investigation into potential criminal activities, including market manipulation and the creation of synthetic shares.
5. Encouraging legislative reforms to strengthen oversight mechanisms for self-regulatory organizations like FINRA.
This matter is more than a financial issue; it is a question of justice and the fundamental trust that underpins our democratic and economic systems. I am also in the process of disseminating an open letter to lawmakers, media outlets, and advocacy groups to build a broader coalition for action. I believe your voice and influence can be pivotal in accelerating efforts to resolve this crisis and restore public confidence in our markets. I understand that, as the leader of the free world, you have thousands of priorities competing for your attention. However, one phone call or email from your office could change the tide for 65,000 investors who have endured two years of being dismissed, ignored, and left to endure significant fiscal and emotional damage.
I have attached a copy of the executive summary for the open letter for your review. This letter is being sent to the senators of the U.S. Senate Committee on Finance through our respective elected senators and representatives from our home states.
I thank you for your time and consideration and remain hopeful for your support in this critical matter.
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[UPDATE 2 - 2025 01 24 [(X-SUM FINAL COPY)]
This executive summary is a pre-read provided to members of Congress in advance of the full petition and open letter, scheduled for release on or around February 1, 2025. It outlines the systemic regulatory failures surrounding the December 2022 MMTLP trading halt and deletion, highlighting the financial and systemic damage caused to tens of thousands of investors. This summary is intended to prepare lawmakers for the detailed requests in the full letter, which include Congressional oversight, GAO and DOJ investigations, and reforms to restore trust in U.S. financial markets is sent out Friday, 24 January 2025. This is the final version.
It reads as follows; the open letter itself is beyond the last update below.
TO: U.S. Senate Committee on Finance Members and Esteemed Lawmakers: Chairman Senator Mike Crapo (R-ID), Ranking Member Senator Ron Wyden (D-OR), and all member Senators; Chuck Grassley (R-IA), John Cornyn (R-TX), John Thune (R-SD), Tim Scott (R-SC), Bill Cassidy (R-LA), James Lankford (R-OK), Steve Daines (R-MT), Todd Young (R-IN), John Barrasso (R-WY), Ron Johnson (R-WI), Thom Tillis (R-NC), Marsha Blackburn (R-TN), Roger Marshall (R-KS), Maria Cantwell (D-WA), Michael Bennet (D-CO), Mark Warner (D-VA), Sheldon Whitehouse (D-RI), Maggie Hassan (D-NH), Catherine Cortez Masto (D-NV), Elizabeth Warren (D-MA), Bernie Sanders (I-VT), Tina Smith (D-MN), Ben Ray Luján (D-NM), Raphael Warnock (D-GA), and Peter Welch (D-VT).
THRU: Our Elected Representatives: Senator Andy Kim (D-NJ), Senator Cory Booker (D-NJ), Representative Josh Gottheimer (D-NJ), Senator Ashley Moody (R-FL), Senator Rick Scott (R-FL), Representative Maxwell Frost (D-FL), Senator John Cornyn (R-TX), Senator Ted Cruz (R-TX), Representative Lizzie Fletcher (D-TX), Representative Ralph Norman (R-SC), Representative Pete Sessions (R-TX).
FROM: SGM Daniel R. Auxier (NJ), Mr. Marcos Monteiro (FL), Mr. Brad Davis (TX)
DATE: January 24, 2025
SUBJECT: Executive Summary for Open Letter Addressing the December 9, 2022, MMTLP Trading Halt, December 13, 2022, Deletion, and Lack of Comprehensive Response to Congressional Inquiries from Representative Ralph Norman (R-SC) and Representative Pete Sessions (R-TX) (December 22, 2023, and June 5, 2024) by SEC and FINRA
1. Background. The open letter highlights FINRA’s issuance of a U3 trading halt without adequate explanation, followed by the deletion of the MMTLP ticker. These actions created systemic uncertainty, leaving investors unable to reconcile their holdings. Regulatory bodies, including FINRA, the SEC, and the DTCC, have failed to address issues such as synthetic shares, settlement discrepancies, and failures to deliver (FTDs), worsening investor harm. Despite the SEC’s awareness of these irregularities since 2021 and receiving over 56,000 emails and 848 complaints, 0.1% have received a response. This inaction violates the SEC’s mission to protect investors and maintain fair markets, highlighting the need for Congressional oversight.
2. Scope of Damage. The MMTLP trading halt and ticker deletion have caused extensive and deeply personal harm. Tens of thousands of investors have suffered significant financial losses, unable to access holdings or liquidate positions. Reports include suicides, fractured relationships, and a toxic environment within the X MMTLP community, marked by groupthink, cyberbullying, and harassment through doxxing and sharing of personal information. These behaviors have deepened the emotional toll, creating a climate of fear and distrust. Beyond individual harm, this crisis has eroded public confidence in U.S. financial markets, exposing systemic vulnerabilities that demand urgent attention. Immediate resolution is essential to support the affected community and restore trust in the regulatory system.
3. Purpose. This open letter addresses unresolved systemic failures stemming from the December 9, 2022, trading halt and December 13, 2022, deletion of MMTLP shares. These actions by FINRA, compounded by the SEC and DTCC’s prolonged inaction, have left tens of thousands of investors without resolution or recourse, undermining trust in the U.S. financial system. The letter draws attention to the original congressional inquiry led by Representative Ralph Norman (R-SC) and 74 co-signers on December 22, 2023, and a follow-up memo on June 5, 2024. Despite the significant time elapsed—over 400 days—no meaningful public action or accountability has followed, leaving investors in financial and legal limbo.
4. Request for Information. The letter requests detailed information regarding the decisions and actions taken by FINRA, the SEC, and the DTCC in relation to the December 9, 2022, U3 trading halt and subsequent deletion of the MMTLP ticker. Specifically, it seeks transparency on the rationale behind the halt, reconciliation of outstanding trades and synthetic shares, and efforts to address failures to deliver (FTDs). It also requests access to trading data (such as “Blue Sheets”), internal communications, and compliance documentation related to MMTLP and associated entities. Additionally, we would like to see any communications or information (redacted, if necessary) that Representative Norman and Congress have pursued to obtain answers and resolutions. Providing this evidence would demonstrate that this matter is being taken seriously, without requiring the submission of a FOIA request and the associated delays.
5. Request for Action. The letter urges Congress to take swift and decisive action to address the regulatory failures perpetuating the MMTLP crisis. It calls for a Government Accountability Office (GAO) investigation into the civil failings of FINRA, the SEC, and the DTCC, as well as a Department of Justice (DOJ) investigation into potential criminal activities, including market manipulation, synthetic share creation, and other violations. The letter also emphasizes the need for a forensic audit of MMTLP activity, the release of detailed trading data, and legislative reforms to strengthen oversight of self-regulatory organizations and improve protocols for extraordinary trading halts. Moreover, online activity on X must be investigated for evidence of influencers being paid by third parties to manipulate public narratives, intimidate individuals, or discourage participation in litigation and investigations. These tactics, such as doxxing—exposing confidential information to harass, bully, or silence—pose a serious threat to accountability. Finally, the letter requests a public hearing similar to the one held for GameStop and a formal meeting in Washington, D.C., with representatives and the SEC to directly address these critical issues with the open letter undersigned and petitioners present, if willing and able.
6. Conclusions. The MMTLP matter exemplifies systemic failings that demand immediate Congressional action. This open letter urges Congress to fulfill its oversight responsibilities, hold regulatory bodies accountable, and secure restitution for affected investors. The crisis has already spurred numerous lawsuits across multiple jurisdictions, exposing widespread harm and unresolved issues. As regulatory inaction persists, a third wave of legal filings is likely, signaling an escalating demand for justice and accountability. Additionally, online activity on X has been used by influencers, potentially paid by third parties, to manipulate narratives, intimidate individuals, and suppress shareholder collaboration through tactics such as doxxing. These actions further demonstrate the systemic nature of the crisis, which extends beyond two CEOs to include the actions and inactions of the transfer agent, broker-dealers, market makers, and regulators. All these elements must be thoroughly investigated to ensure accountability and systemic reform.
7. Notice. This executive summary serves as a read-ahead copy of the open letter, which is mailed and emailed to your respective offices no later than February 1, 2025. The open letter includes attached petition signatories and detailed supporting evidence. A full copy of the letter is also available for public viewing and download at www.change.org/resolveMMTLPnow
8. Open Letter. To ensure widespread awareness and total transparency, copies of the open letter are being shared with major news outlets, financial publications, investigative journalists, and relevant public platforms. The letter is also being disseminated to advocacy groups, legal professionals, regulatory experts, and the public online to foster a broader coalition for action. Its goal is to amplify the voices of affected investors, draw attention to systemic regulatory failures, and push for meaningful resolution and reform.
9. Acknowledgement. Please confirm receipt of the accompanying email and this attachment.
10. Point of Contact. For further questions, comments, or concerns, the undersigned can be contacted at (XXX) XXX-XXXX or XXXXXX@XXXX.com.
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[UPDATE 1 - 2025 01 17]
At the request of many, a TL;DR (too long, didn't read) of this open letter is as follows;
The open letter, addressed to Congress and regulatory bodies, details unresolved issues surrounding the December 2022 halt and deletion of the MMTLP ticker. It highlights:
1. Regulatory Failures: FINRA's indefinite trading halt and deletion of MMTLP shares without clear explanation, coupled with the SEC's inaction despite over 848 complaints, more than 56,000 emails submitted by concerned investors, and FOIA evidence of irregularities since 2021.
2. Investor Harm: Tens of thousands of investors have been left without recourse or clarity, eroding trust in financial markets. The SEC's lack of response and FINRA's failure to enforce rules exacerbated financial losses.
3. Systemic Issues: Evidence points to market manipulation, synthetic shares, and unresolved failures to deliver (FTDs). FINRA and the DTCC are criticized for inadequate oversight and accountability.
4. Legal and Constitutional Concerns: Actions by FINRA and the SEC are described as unconstitutional, denying due process and violating shareholder rights. Multiple lawsuits are cited, reflecting the scale of investor grievances.
5. Call to Action: The letter demands congressional hearings, a GAO investigation, DOJ intervention, and comprehensive reforms to address regulatory negligence, restore investor confidence, and prevent future crises.
Special Note: The document also includes minor criticism of former Torchlight Energy CEO John Brda and key figure Greg McCabe for not negoating positive results or resolving the situation. Additionally, Next Bridge Hydrocarbons (NBH) is called out for failing to respond to official shareholder requests for information, further compounding investor frustrations and leaving unresolved questions. Despite this information being 2.4% of the total documents text and objectively factual in nature, this note has been added based on others feedback. Please remember to read all of the document before signing. Thank you.
...
[THE OPEN LETTER - 2025 01 15]
Distinguished Lawmakers and Esteemed Representatives,
We write this open letter to bring to your attention the unresolved and critical issues surrounding the trading halt and eventual deletion of the Meta Materials Torchlight Preferred Shares (MMTLP) ticker. On December 9, 2022, FINRA issued a U3 trading halt, freezing all trading activities without prior notice or adequate explanation. Just days later, on December 13, 2022, the MMTLP ticker was deleted, leaving tens of thousands of investors unable to access or reconcile their holdings. These events exemplify systemic regulatory failures, encompassing systemic manipulation, regulatory negligence, and breaches of fiduciary duty. The MMTLP case presents a monumental challenge to the trust and integrity of U.S. financial markets.
The issues arising from the MMTLP halt highlight a series of profound missteps and structural flaws. FINRA's actions, including the indefinite halt citing “extraordinary events” without substantive explanation, underscore the unchecked powers of self-regulatory organizations and the failure of oversight bodies like the SEC to intervene effectively. This lack of clarity and accountability has left investors in limbo for over two years, further eroding confidence in our financial system. As individuals deeply affected by this crisis, alongside tens of thousands of investors, we implore Congress and regulatory bodies to address this injustice with urgency and transparency.
The SEC was aware of potentially fraudulent activities affecting MMTLP as early as 2021, well before the December 9, 2022, trading halt and the subsequent deletion of the ticker on December 13, 2022. Despite receiving 848 formal complaints and over 56,000 emails from concerned investors—facts uncovered through Freedom of Information Act (FOIA) requests—the Commission has taken no meaningful steps to resolve the issue. To date, only 35 complaints have received an official response, representing a dismal 0.06% resolution rate. This negligence underscores the SEC's failure to fulfill its fundamental mandate to protect investors and maintain fair and transparent markets, even two years after the halt.
FINRA and DTCC are equally culpable, having failed to enforce existing regulations, address short positions, and resolve discrepancies in share reconciliation. These entities must be held accountable for their roles in exacerbating the harm to investors. Regulatory bodies cannot be allowed to operate without consequence when their actions—or lack thereof—directly undermine public trust and market integrity. Congress must demand a full accounting of their decisions and take steps to ensure these failures are not repeated.
The Financial Industry Regulatory Authority (FINRA) compounded the harm by failing to follow its own rules, including those governing the settlement of short positions. FINRA's Rule 504 requires the prompt close-out of short positions in specific circumstances, yet no such actions were taken to enforce compliance in the wake of the trading halt. This failure to enforce existing regulations has left investors with unresolved and increasingly detrimental financial positions. Moreover, FINRA's decision to issue an indefinite halt, citing vaguely defined “extraordinary events,” and its subsequent deletion of the MMTLP ticker without a clear and transparent process, reflect a lack of accountability and procedural fairness. These actions highlight systemic flaws in the governance and oversight of self-regulatory organizations.
The unprecedented actions taken by FINRA in relation to the MMTLP trading halt and subsequent deletion of the ticker reveal significant irregularities in the handling of this corporate action. According to evidence from the case file, the Uniform Practice Code (UPC) Committee played a central role in determining the halt, citing an “extraordinary event” as justification. However, the corporate action surrounding MMTLP was unique and anomalous, differing starkly from standard procedures. The decision to halt trading indefinitely and delete the ticker entirely deviated from established norms, as similar corporate actions have historically allowed for orderly resolution and settlement of positions. FINRA’s failure to provide a transparent explanation or follow standard practices raises serious concerns about the integrity and impartiality of the UPC Committee’s decision-making process. The lack of clarity surrounding this corporate action has left investors in financial limbo, compounding the perception of regulatory failure and eroding confidence in the fairness of market oversight.
The handling of the MMTLP case raises significant constitutional concerns, including the unlawful taking of private property without due process. By effectively erasing the value of MMTLP shares and denying investors access to their holdings, regulatory bodies and their subordinate self-regulatory organizations have engaged in an arbitrary and excessive exercise of power. Over the past three years, these entities have consistently demonstrated a lack of transparency, failed to provide substantive justifications for their actions, and denied affected investors their right to fair treatment under the law. This prolonged inaction and disregard for due process not only violate fundamental legal principles but also undermine public trust in the integrity of the financial system. It is imperative that Congress and regulatory agencies address these failings with urgency and transparency to restore confidence and ensure accountability.
The involvement of the Depository Trust & Clearing Corporation (DTCC) further complicates the MMTLP case, as its role in the settlement process underscores critical accountability gaps. As a central clearing organization responsible for ensuring the smooth transfer of securities, the DTCC failed to address unresolved failures to deliver (FTDs) and discrepancies in share reconciliation, exacerbating investor harm. This lack of oversight and enforcement highlights vulnerabilities in a system where key market participants operate without adequate checks, leaving investors with no recourse and deepening the financial and legal uncertainties caused by the halt.
The ongoing case, Davis v. Next Bridge Hydrocarbons, Inc. et al. (Case No. 3:24-cv-03058), alleges systemic issues that have compounded the MMTLP crisis. This case highlights significant failures by the Depository Trust & Clearing Corporation (DTCC) in managing settlement processes, resulting in gaps in accountability and transparency. It further exposes unresolved failures to deliver (FTDs) and discrepancies in the settlement process that have intensified investor harm. The lawsuit seeks to address these critical shortcomings and advocates for meaningful reforms to ensure fair and transparent market operations. The evidence points to a troubling pattern of systemic manipulation. Synthetic shares—created through improper trading practices—flooded the market, artificially inflating the share supply and suppressing prices. The trading volume for MMTLP far exceeded the authorized float of 165 million shares, suggesting the proliferation of counterfeit shares. FOIA-released documents reveal that both the SEC and FINRA were aware of these irregularities as early as November 2021 but failed to act decisively. This inaction allowed market manipulation to persist, eroding investor confidence and undermining market integrity.
The governance structure of FINRA adds another layer of complexity and concern. As a self-regulatory organization wielding quasi-governmental authority, FINRA’s unilateral actions, such as the U3 halt, lack the checks and balances typically applied to federal agencies. This governance model raises constitutional questions, particularly under the separation of powers doctrine. The lack of meaningful oversight over FINRA’s decisions has left investors with no recourse and exacerbated the harm caused by the halt.
The ongoing case, Auxier v. SEC (Case No. 7:24-CV-318), alleges systemic failures that have exacerbated the MMTLP crisis. This case exposes significant lapses in regulatory oversight, particularly by the Securities and Exchange Commission (SEC), in its failure to enforce compliance by the Financial Industry Regulatory Authority (FINRA) and the Depository Trust & Clearing Corporation (DTCC). It argues unresolved failures to prevent or address the proliferation of synthetic shares, which flooded the market, artificially inflated share supply, and suppressed prices. These manipulative practices created significant discrepancies in share ownership and left countless investors unable to reconcile their holdings.
The lawsuit further challenges the SEC’s inaction, despite documented evidence of fraudulent activities related to MMTLP as early as November 2021. Freedom of Information Act (FOIA) documents reveal that the SEC and FINRA were aware of these irregularities yet failed to take meaningful steps to investigate or resolve the issues. This inaction allowed synthetic shares and failures to deliver (FTDs) to persist unchecked, undermining investor confidence and market integrity.
The case also raises broader implications for market fairness and governance, particularly highlighting constitutional concerns regarding FINRA’s quasi-governmental authority and lack of oversight. By advocating for reforms, the lawsuit seeks to hold the SEC accountable for its failures and ensure greater transparency and accountability within regulatory bodies. Through these efforts, Auxier v. SEC aims to address systemic shortcomings and restore fairness to U.S. financial markets.
The scale of public outcry over MMTLP’s halt has been unprecedented. On December 22, 2023, Representative Ralph Norman led a bipartisan coalition of 74 members of Congress in a letter to the SEC and FINRA, demanding answers and accountability. Despite Congress receiving over 40,000 complaints from affected investors, there has been little progress or meaningful engagement from regulatory bodies. The lack of resolution not only damages the financial wellbeing of investors but also undermines public trust in regulatory institutions.
Additionally, corporate leadership, including figures such as John Brda and Greg McCabe, have failed to take meaningful action to address shareholder concerns. While McCabe continues to play a role in related enterprises, both he and other executives have yet to offer legal solutions or advocate effectively through lawmakers for investors trapped in this debacle. This absence of accountability among corporate officers further highlights the systemic issues plaguing the MMTLP case.
Adding to the frustration, Next Bridge Hydrocarbons has consistently failed to respond to shareholder concerns or provide substantive updates. Despite multiple formal requests for information and accountability, as shareholders, the company has avoided addressing critical issues related to share reconciliation and investor grievances. This lack of communication has compounded the distress faced by affected investors and underscores the broader failures of governance and transparency within this matter.
The lack of action from regulatory bodies, corporate leadership, and other financial market entities compounds the financial and emotional distress of MMTLP shareholders. Investors have remained trapped in a situation where neither governmental agencies nor corporate entities provide clear paths to resolution. For instance, despite multiple inquiries regarding share ownership discrepancies and the processes for transitioning assets, Next Bridge Hydrocarbons has offered no viable solutions. The systemic failures have left many investors feeling abandoned, further eroding their trust in the fairness of the U.S. financial system.
The widespread fallout from the MMTLP matter has led to a surge of legal actions across various jurisdictions, underscoring the systemic failures that have affected tens of thousands of investors. Among the notable cases is Pease v. SEC (No. 7:24-cv-00322-DC), filed in the U.S. District Court for the Western District of Texas, which highlights regulatory negligence by the SEC and its failure to act on fraudulent market activities. Similarly, Spears v. Next Bridge Hydrocarbons, Inc. (No. 7:24-cv-321), also in the Western District of Texas, focuses on corporate governance failures and the lack of accountability in resolving investor grievances tied to Next Bridge Hydrocarbons. The Vetrano v. Brda case (No. 7:24-cv-325) sheds light on alleged mismanagement by corporate officers, amplifying concerns about fiduciary responsibilities and shareholder protection. Additionally, SEC v. Brda reveals the regulatory agency’s focus on addressing specific allegations of misconduct related to corporate leadership, further illustrating the complex and pervasive nature of the crisis.
Additional cases further expose the pervasive nature of the crisis. Rolo v. SEC (No. 3:24-cv-02053), brought in the U.S. District Court for the District of Connecticut, challenges the SEC’s oversight and its failure to prevent or address market irregularities. Willcot v. SEC (No. MO:24-cv-317), filed in the Western District of Texas, similarly targets regulatory shortcomings, calling into question the efficacy of current oversight mechanisms. The Inter-Coastal Waterways LLC v. TradeStation Securities, Inc. (No. 0:24-cv-60891), in the U.S. District Court for the Southern District of Florida, highlights discrepancies in brokerage practices, particularly failures in reconciling investor accounts and enforcing market regulations.
Further emphasizing the national scope of this issue is Taggart v. Next Bridge Hydrocarbons, Inc. (No. 1:24-cv-01927), brought in the U.S. District Court for the Eastern District of New York. This case raises critical questions about the actions of corporate entities in the wake of the trading halt and ticker deletion. Traudt v. Rubenstein et al. (No. 2:24-cv-00782), filed in the U.S. District Court for the District of Vermont, delves into the systemic creation of synthetic shares and the impact of these practices on market integrity and investor confidence. Together, these cases paint a comprehensive picture of the legal challenges surrounding the MMTLP matter, demanding urgent action to address the structural flaws and systemic failures that have harmed investors across the country.
Finally, as mentioned above, the SEC v. Brda case pertains to actions involving Torchlight Energy Resources (TRCH), the predecessor to MMTLP, rather than MMTLP directly. Torchlight Energy Resources merged with Meta Materials Inc. (MMAT) in 2021, forming the backdrop for the issuance of MMTLP shares. During and after the merger, both TRCH and MMAT experienced unusual and anomalous stock activity. Despite this, the SEC's actions related to these issues have not produced any substantive results or public updates in over two years.
While the investigation into the alleged actions of John Brda and George Palikaris might suggest regulatory engagement, it falls far short of addressing the broader systemic issues at play. Targeting a few individuals as scapegoats does little to resolve the widespread failures of oversight and enforcement that allowed the MMTLP crisis to unfold. The focus on these individuals serves as a symbolic gesture rather than a meaningful effort to hold accountable the institutions, regulators, and market participants who enabled the proliferation of synthetic shares, market manipulation, and regulatory negligence. By concentrating on a narrow investigation, the SEC diverts attention from its own inaction and the larger systemic failures that continue to harm investors and undermine confidence in U.S. financial markets. A genuine effort to restore trust requires a comprehensive investigation into all actors and entities involved—not just the convenient targeting of a few.
Additionally, the SEC has acknowledged through official documents that an investigation is ongoing into actions and parties connected with MMTLP. Despite this investigation being active for approximately two years, no public results or updates have been released. Meanwhile, investors are left waiting for clarity and answers from the SEC. During this prolonged period of inaction, the statute of limitations may begin to toll, potentially stripping investors of their legal rights to file lawsuits against involved parties.
The handling of the MMTLP trading halt and subsequent deletion represents a stark violation of basic shareholder rights. Shareholders have a fundamental right to access timely and accurate information about their investments, participate in corporate decision-making, and seek redress in cases of suspected misconduct. In this case, the sudden U3 halt imposed by FINRA, followed by the deletion of the MMTLP ticker, denied investors the ability to react or even understand the reasons behind these actions. The lack of transparency, coupled with the absence of an adequate explanation, left shareholders without recourse and exacerbated financial harm, undermining the trust and confidence that are critical to functioning financial markets.
Compounding the harm is the prolonged inaction of the SEC, which has failed to provide any meaningful updates or results from its admitted ongoing investigation into MMTLP and related parties. Shareholders have waited for over two years, during which time critical statutes of limitations may begin to toll, effectively removing their ability to pursue legal remedies. This inaction denies shareholders their right to accountability and justice while regulatory agencies, which are tasked with protecting investors, fail to fulfill their mandates. These systemic failures demand immediate congressional oversight and action to restore fairness, transparency, and investor confidence in U.S. financial markets.
The need for action is clear and urgent. To address the systemic issues outlined in this memorandum, we recommend the following steps. Transparency must be prioritized. Detailed trading data, such as “Blue Sheets,” should be released to clarify the extent of trading irregularities and the proliferation of synthetic shares. Legislative reforms are needed to strengthen oversight mechanisms for self-regulatory organizations, ensuring their actions are subject to meaningful review and accountability. Protocols must be established to address extraordinary trading halts, with clear timelines and mandatory disclosures to affected parties. Finally, a comprehensive forensic audit of MMTLP trading records is essential to identify and rectify discrepancies and to restore investor confidence.
We formally request a Congressional Hearing akin to those held during the GameStop controversy, as the issues uncovered during that incident pale in comparison to the MMTLP fiasco. With over 65,000 investors affected, the scale and severity of the systemic failures surrounding MMTLP—including the proliferation of synthetic shares, regulatory negligence, and the deletion of the ticker—demand a thorough and public examination. A hearing is critical to understanding the root causes of these failures, holding accountable the parties responsible, and implementing the necessary reforms to ensure transparency, fairness, and confidence in U.S. financial markets.
It is imperative for Congress to exercise its oversight authority to address this regulatory breakdown. When agencies like the SEC and FINRA fail to protect investors and uphold market integrity, it is Congress's responsibility to intervene. By taking decisive action, you can reaffirm the accountability of these institutions and restore public confidence in the financial system.
We respectfully request that Congress initiate a Government Accountability Office (GAO) investigation into the practices and oversight mechanisms of FINRA, the Depository Trust & Clearing Corporation (DTCC), and the Securities and Exchange Commission (SEC). This investigation should examine systemic failures, including regulatory gaps, lack of accountability, and potential conflicts of interest that have exacerbated the MMTLP crisis.
We urge the Department of Justice (DOJ) to intervene and investigate possible violations of federal securities laws, including allegations of market manipulation, synthetic share creation, and failures to deliver (FTDs). These actions are essential to restoring public trust in our financial markets, holding responsible parties accountable, and preventing similar injustices in the future.
We, the undersigned, request a meeting in Washington, D.C., to discuss these issues with the SEC and our congressional representatives. This meeting, which should include our legal counsel and theirs, would provide an opportunity to address, and perhaps settle, any unresolved trading irregularities, explore compensation mechanisms for investors, and develop actionable plans for regulatory reforms. We believe such engagement is critical to achieving justice for MMTLP investors and to restoring trust in our financial system.
As we approach more than two years since the MMTLP trading halt, the absence of resolution continues to harm thousands of investors and casts a long shadow over the integrity of U.S. financial markets. This case offers Congress and regulatory agencies a unique opportunity to demonstrate their commitment to transparency, fairness, and accountability. By addressing the systemic failures that have defined the MMTLP matter, you can help rebuild public confidence in our markets and ensure that such injustices are not repeated.
We urge you to take immediate action to resolve this matter, provide restitution to affected investors, and implement the necessary reforms to safeguard market integrity. Together, we can ensure that our financial markets remain a cornerstone of fairness, transparency, and opportunity for all participants.
We have attached copies of the last two congressional memos regarding concerns for MMTLP for your records and review. These memos dated December 22, 2023, and June 5, 2024, highlight the breadth of concern among our lawmakers and the urgency of addressing the systemic issues surrounding MMTLP. To our knowledge, no public action has been taken in response to these memos, aside from a brief public exchange with SEC Chairman Gary Gensler. During this conversation, between Ralph Norman and Chairman Gensler, the chairman failed to provide any meaningful insights, solutions, or even an apology to the tens of thousands of investors affected by this ongoing crisis. This lack of response underscores the need for immediate and decisive action. The lack of comprehensive responses to congressional inquiries is deeply troubling and raises questions about the accountability mechanisms in place for regulatory agencies.
If it were me, or any other citizen or government employee standing before Congress, such a lack of transparency or accountability would likely have been met with far greater scrutiny and consequences. This disparity is not lost on the public, and I trust that you understand the frustration and sense of injustice it fosters. I respectfully urge you to recognize this imbalance and take meaningful steps to address it.
The SEC has had over three years to address and resolve the MMTLP fiasco, both before and after FINRA’s imposition of the U3 halt and subsequent deletion of the ticker. The Commission suffers from no shortage of knowledge, resources, authority, or funding—yet it has failed to fairly resolve what should be a straightforward matter: a preferred stock dividend from a relatively obscure oil and gas exploration company. This glaring inaction raises a critical question: if the SEC cannot competently address this relatively contained issue in a timely manner, how can it be expected to handle far larger market challenges or respond effectively to emerging financial contingencies? The inability to resolve this crisis undermines confidence not only in the SEC but also in the broader regulatory framework designed to protect investors and ensure market integrity.
...
Please note: An official signed memorandum from the authors is sent to their respective congressional and gubernatorial offices, with this petition's signatories attached as a record of their endorsement of this open letter.

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Petition created on January 15, 2025