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A security in distribution is convertible into an actively-traded security. Is the security in distribution subject to a restricted period under Rule 101?

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A security in distribution is convertible into an actively-traded security. Is the security in distribution subject to a restricted period under Rule 101?

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Yes. The ADTV value of the subject security determines the restricted period. The ADTV value of a reference security does not affect the restricted period of a subject security.

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