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A hedge fund shorts shares five days before pricing a follow-on offering and asks for an allocation at the offering price. What should the principal do?
Document best execution under FINRA Rule 5310 and ignore customer-order priority.
File Form ATS because the issue involves electronic order routing or trading technology.
Apply Regulation M Rule 105 and block prohibited offering allocation unless an exception applies.
Treat it only as a Regulation S-P privacy notice issue and send an annual privacy notice.
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