NakedShortStop™
NSSR #-001
Case File: MMTLP – The FINRA U3 Trading Halt
🟢 Status: Active Report
First Published: July 2026
Last Updated: August 26, 2026
NAKEDSHORTSTOP™ SPECIAL REPORT
MMTLP
The Last Two Trading Days
December 9, 2022.
A little-known OTC security called MMTLP stopped trading without warning.
The halt came just days before the security was scheduled to disappear forever, converting into shares of the private company Next Bridge Hydrocarbons. Thousands of investors believed they still had two trading days remaining. They never got them.
What followed was years of controversy, congressional inquiries, Freedom of Information disputes, lawsuits, sworn declarations, and an expanding body of evidence that continues to raise difficult questions about one of the most unusual trading halts in modern market history.
Was the halt simply an extraordinary regulatory response to an extraordinary market event? Or did it interrupt the normal settlement process before critical questions about outstanding positions could be answered?
Nearly three years later, many of those questions remain unresolved.
This report examines the evidence.
LATEST DEVELOPMENTS
AUGUST 25, 2026 — NEXT BRIDGE SAYS SEC AND FINRA HAVE NOT RESPONDED
Next Bridge says attempts to meet with both the SEC and FINRA to present what it describes as evidence of unauthorized shares created by U.S. broker-dealers have not resulted in a response or meeting. The company says it is now exploring available legal avenues while continuing to seek a regulatory resolution.
JULY 28, 2026 — NEXT BRIDGE RELEASES BROKER-LEVEL SHARE REGISTRATION DATA
Following distribution of its special stock dividend, Next Bridge released broker-level bulk-certificate share registration data maintained at transfer agent Equiniti. The company said the registered totals at several firms did not accurately reflect shares it believes were actually credited to brokerage customers – adding a new source of evidence to the unresolved question of MMTLP share reconciliation.
Report at a Glance
Status: Version 1.0 — Living Report
Evidence Files: 11
Central Event: FINRA U3 Trading Halt
Key Issue: Final two trading days and share reconciliation
Primary Question: Where is the reconciled share count?
The following primary source documents form the evidentiary foundation of this report. Each document is examined independently under The Veritas Standard to distinguish established facts, regulatory statements, judicial findings, allegations, and unresolved questions.
Last updated: August 26, 2026
The Questions That Remain
This report seeks to address the following questions based upon publicly available information:
- Why was a FINRA U3 Extraordinary Event Trading Halt imposed on December 8, 2022?
- What public information explains the timing and scope of the trading halt?
- Can the publicly available records reconcile the number of issued shares, beneficial ownership, and settlement obligations?
- Which relevant records are publicly available, and which remain unavailable?
- Would additional transparency improve public confidence in the outcome?
Transparency Assessment
The following assessment summarizes the availability and completeness of publicly accessible information reviewed for this report. It is intended to identify where transparency exists, where it is limited, and where significant questions remain.
| Category | Transparency Status |
| FINRA Trading Halt Notice | Available |
| SEC Filings | Available |
| Company Disclosures | Available |
| Court Records | Available |
| Trading Data | Partial – Public data exists but is incomplete. |
| Share Count Reconciliation | Partial – The Next Bridge disclosure adds information, but a full reconciliation is still not publicly possible. |
| Beneficial Ownership Transparency | Partial – Beneficial ownership remains incomplete. |
| Settlement Transparency | Partial – Public records still don’t provide complete settlement visibility. |
★ Developing Story: The status of Share Count Reconciliation has been updated from “Not Publicly Verified” to “Partial” following recent public disclosures by Next Bridge Hydrocarbons. While these disclosures provide additional transparency, they do not yet constitute a complete independent reconciliation of issued shares, beneficial ownership, or settlement obligations. This assessment may be updated as further publicly available information emerges.
Key Observation
Public records provide substantial information regarding the MMTLP trading halt, company disclosures, regulatory filings, and court proceedings. However, several questions frequently raised by investors—such as complete share reconciliation, beneficial ownership, and final settlement transparency—cannot currently be independently verified using publicly available records alone.
Background
The events surrounding MMTLP did not begin with the December 2022 trading halt.
They began several years earlier with a corporate merger involving Torchlight Energy Resources and Meta Materials Inc. As part of that transaction, Torchlight shareholders received preferred shares representing potential future value tied to Torchlight’s oil and gas assets.
Those preferred shares were never intended to become a widely traded public security. Yet over time they began trading over-the-counter under the symbol MMTLP, creating a market that neither company had originally anticipated.
In 2022, Meta Materials announced that the remaining oil and gas assets would be spun out into a new private company, Next Bridge Hydrocarbons. Existing MMTLP shareholders would receive shares of the private company, ending public trading in MMTLP.
Ordinarily, that would have marked the conclusion of an unusual corporate action.
Instead, the final days of trading became the beginning of a controversy that continues today.
An Unexpected Market
One of the central questions surrounding MMTLP is how public trading in the security began. Some investors believed a Form 211 must have been filed with FINRA to initiate quotations. FINRA has since stated publicly that it did not receive a Form 211 relating to MMTLP.
Instead, FINRA states that broker-dealers relied upon an exception contained in SEC Rule 15c2-11 that permits quotations for unsolicited customer orders rather than submitting a Form 211.
Although this explains FINRA’s regulatory position, it leaves several questions unresolved, including:
- Which broker-dealers first relied on the unsolicited quotation exception?
- What documentation supported that decision?
- How did quotations become sufficiently established for broader OTC market activity?
- What communications, if any, occurred among FINRA, broker-dealers, and market participants regarding the commencement of trading?
These questions remain important because they relate directly to the origin and regulatory history of MMTLP.
Chronology
| Date | Event |
| June 28, 2021 | Meta Materials Inc. completes its merger with Torchlight Energy Resources. |
| October 2021 | MMTLP begins trading on the OTC market. |
| November 2022 | Meta Materials announces the distribution of Next Bridge Hydrocarbons shares. |
| December 6, 2022 | Final trading guidance issued ahead of the corporate action. |
| December 6, 2022 | FINRA issues a U3 Extraordinary Event Trading Halt. |
| December 9, 2022 | MMTLP remains halted; investors are unable to trade. |
| December 14, 2022 | Distribution of Next Bridge Hydrocarbons shares is completed. |
Post-Trading Developments
| June 24, 2026 | Next Bridge announces a 1-for-30 special stock dividend, establishing July 8 as the record date and July 22 as the distribution date. |
| June 29, 2026 | Next Bridge issues additional guidance concerning eligibility, registered shares, brokerage bulk certificates, and distribution of the special dividend. |
| July 13, 2026 | Next Bridge reports another effort to engage senior SEC officials regarding what it describes as an unresolved MMTLP share-ledger imbalance. |
| July 17, 2026 | Next Bridge provides distribution guidance after Equiniti confirms that directly registered accounts and brokerage bulk certificates are scheduled to receive the dividend. |
| July 22, 2026 | Special stock dividend is distributed through Equiniti; responsibility for allocation to individual brokerage accounts rests with the respective brokerage firms. |
| July 28, 2026 | Next Bridge releases broker-level bulk-certificate registration data and says totals registered at several firms do not accurately reflect shares it believes were credited to brokerage customers. |
| August 25, 2026 | Next Bridge says efforts to meet with the SEC and FINRA to present what it describes as evidence of unauthorized shares have not resulted in a response or meeting. |
Evidence Files
The following documents form the primary evidentiary record reviewed in this report. Wherever possible, readers are encouraged to examine the original source material before considering NakedShortStop’s analysis and conclusions.
PSD-001 – FINRA U3 Extraordinary Event Trading Halt
Source
Financial Industry Regulatory Authority (FINRA)
Date Issued: December 8, 2022
Primary Source Document Excerpt:
Attn: Trading and Market Making/Legal and Compliance/Operations/Systems UNIFORM PRACTICE ADVISORY (UPC # 35-22) 12/09/2022 Trading and Quotation Halt for META MATERIALS PFD SER A (MMTLP) Effective Friday, December 09, 2022, the Financial Industry Regulatory Authority, Inc. (“FINRA”) halted trading and quoting in the Series A preferred shares of Meta Materials Inc. (OTC Symbol: MMTLP). Pursuant to Rule 6440(a)(3), FINRA has determined that an extraordinary event has occurred or is ongoing that has caused or has the potential to cause significant uncertainty in the settlement and clearance process for shares in MMTLP and that, therefore, halting trading and quoting in MMTLP is necessary to protect investors and the public interest. The trading and quoting halt will end concurrent with the deletion of the symbol effective Tuesday, December 13, 2022. See updated FINRA Daily List announcement of December 8, 2022, regarding MMTLP; available here: https://otce.finra.org/otce/dailyList. See also Form S1 Registration Statement for Next Bridge Hydrocarbons, Inc. stating that “…immediately after the Spin-Off, all shares of Series A Non-Voting Preferred Stock of Meta shall be cancelled.” Available here: https://www.sec.gov/Archives/edgar/data/1936756/000119312522281275/d302576ds1a.ht m. Questions regarding this notice can be directed to: FINRA Market Operations at (866) 776-0800, Option 2.
Document Summary
On December 8, 2022, FINRA imposed an Extraordinary Event (U3) Trading Halt on Meta Materials Preferred Shares (MMTLP), citing concerns related to the pending corporate action involving the distribution of Next Bridge Hydrocarbons shares.
The halt became effective immediately and prevented further public trading in MMTLP before the anticipated completion of the corporate action.
Why This Document Matters
The FINRA U3 Trading Halt is the central event examined in this report.
Understanding FINRA’s stated rationale, the timing of the halt, and the regulatory framework surrounding the decision is essential to evaluating subsequent questions regarding settlement, shareholder expectations, and market transparency.
Evidence Assessment
The document establishes that FINRA exercised its authority to halt trading under Rule 6440. However, by itself, the notice does not fully explain the basis for the timing of the halt, nor does it resolve questions concerning share reconciliation, settlement obligations, or beneficial ownership records. Those questions require examination of additional documents and publicly available evidence.
PSD-009A – Next Bridge Reports Institutional Share Imbalances
Source: Next Bridge Hydrocarbons, Inc.
Date Issued: January 23, 2024
Primary Source: Next Bridge Hydrocarbons letter to FINRA Chief Legal Officer Robert Colby
Document Summary
On January 23, 2024, Next Bridge Hydrocarbons informed FINRA that it had been gathering data concerning what the company described as an imbalance in its shareholder ledger.
Next Bridge said its early findings suggested a number considerably higher than the approximately 2.65 million shares of aggregate short interest previously identified by FINRA.
The company then disclosed something more consequential.
According to Chairman Greg McCabe, the investment banking firm representing Next Bridge had received several inbound calls from financial institutions seeking to purchase Next Bridge shares in order to bring their books into balance.
McCabe said one inquiry was sufficiently large that he personally joined a call with the institution.
Following that call, McCabe told FINRA that he had knowledge of an admitted shareholder imbalance at one financial institution alone that was multiples greater than 2.65 million shares.
Next Bridge said it was continuing to gather information concerning additional imbalances from multiple sources.
Why This Document Matters
The significance of the letter is not simply that Next Bridge disputed FINRA’s estimate.
According to the issuer, financial institutions themselves were approaching its investment banker seeking Next Bridge shares because their books required balancing.
And according to McCabe, the imbalance acknowledged by one institution alone was multiples greater than FINRA’s entire 2.65-million-share estimate.
That creates a direct and measurable reconciliation question:
If one institution alone reportedly required multiples of 2.65 million shares to bring its books into balance, what did the complete broker-by-broker position ledger show?
The January 23 letter also reaches backward through the history of the security.
Next Bridge specifically referred not only to parties that had sold MMTLP short, but also to parties that had been short Torchlight Energy and carried that short position through the merger with Meta Materials without ultimately providing the corresponding share.
The obligation genealogy therefore becomes:
TRCH → Meta Materials / Series A → MMTLP → Next Bridge
Evidence Assessment
The January 23 letter does not independently establish the total number of unresolved short or delivery obligations.
The statements concerning institutional inquiries and the size of the reported imbalance are assertions made by Next Bridge Chairman Greg McCabe and would require the underlying institutional records for independent verification.
But the letter establishes an important part of the public evidentiary record:
Next Bridge formally told FINRA that financial institutions had approached its investment banker seeking shares to balance their books, and that one institution allegedly acknowledged an imbalance multiples greater than FINRA’s entire 2.65-million-share estimate.
That evidence materially strengthens the case for a complete participant-level reconciliation.
The question is no longer merely how many shares FINRA estimated were short.
The question is whether the books balanced.
Primary document: Next Bridge’s January 23, 2024 letter to FINRA
PSD-010 — Next Bridge Special Dividend / Distribution Documentation
Source
Next Bridge Hydrocarbons, Inc.
Date Range: July 2026
Primary Source Documents
Next Bridge Hydrocarbons issued a series of public updates in July 2026 concerning the distribution of its special stock dividend, the treatment of directly registered shareholders, and the use of brokerage bulk certificates. The company stated that Equiniti Trust Company, LLC, its transfer agent, would distribute the dividend to eligible registered holders and that shares associated with brokerage customers could be issued through bulk certificates registered to individual broker-dealers.
Document Summary
These disclosures document how Next Bridge attempted to distribute the special dividend across two different forms of ownership: directly registered shareholders and investors whose positions were held through broker-dealers.
The distinction is important because directly registered positions could be associated with individual shareholder records maintained by the transfer agent, while brokerage positions could be represented through bulk certificates issued to broker-dealers, leaving the allocation of those shares among individual brokerage customers within the brokers’ own records.
Why This Document Matters
The distribution process is directly relevant to one of the central unresolved questions surrounding MMTLP: whether the shares ultimately distributed through the transfer agent can be fully reconciled with the positions reflected in brokerage customer accounts.
Bulk certificates may establish the number of shares registered to individual broker-dealers, but they do not by themselves establish how those shares were allocated among the underlying beneficial owners. That distinction becomes particularly important when broker-level records and customer positions are compared.
Evidence Assessment
These Next Bridge disclosures provide primary-source documentation of the mechanics used to distribute the special dividend and identify the respective roles of the transfer agent and participating broker-dealers.
Critically, the bulk-certificate structure creates a measurable point of reconciliation: the number of shares registered to each broker-dealer can be compared with the number of shares those firms ultimately credited to their customers. Any material difference between those two figures demands an explanation.
PSD-011 — Next Bridge Broker-Level Share Registration Data
Source
Next Bridge Hydrocarbons, Inc.
Date Issued: July 28, 2026
Primary Source: Next Bridge Hydrocarbons — Next Bridge Hydrocarbons Releases Share Registration Data
Document Summary
On July 28, 2026, Next Bridge Hydrocarbons released broker-level share registration data obtained from its transfer agent, Equiniti Trust Company. The data identifies the number of shares represented by bulk certificates registered at Equiniti to individual brokerage firms as of July 8, 2026, the record date for the company’s special dividend.
Next Bridge also disclosed something considerably more consequential: based upon publicly available information and data from multiple sources, the company said the registered bulk-certificate figures do not accurately reflect the actual number of shares credited to shareholders within several brokerage firms.
What the Data Shows
For example, the Equiniti list contains three separate Charles Schwab registrations:
Broker Shares registered at Equiniti Charles Schwab & Co. Inc. 13 Charles Schwab & Co. Inc. 10,417,569 Charles Schwab & Co. Inc. 17,049,299 Combined 27,466,881
Additional Broker Registrations
National Financial Services and Robinhood Securities also appear prominently in the Equiniti registration data, while other firms appear through multiple registrations. Multiple registrations are not themselves evidence of a discrepancy; they may reflect legitimate custodial or registration structures.
The significance of this disclosure is not the existence of multiple registrations, but Next Bridge’s statement that the registered quantities do not accurately reflect the number of shares credited to customers within certain brokerage firms.
The more consequential disclosure comes from Next Bridge itself: the company states that, based on publicly available information and multiple data sources, the registered bulk-certificate quantities do not accurately reflect the actual total shares credited to shareholders within several firms.
Why This Document Matters
For the first time in the post-MMTLP record, a company has publicly released broker-level registration data while simultaneously asserting that those figures do not accurately represent shares credited to customers at certain brokerage firms.
That creates a concrete reconciliation question.
If a brokerage firm is registered at the transfer agent for one quantity of Next Bridge shares while its customers collectively have been credited with another quantity, the difference requires an explanation.
The critical question is therefore no longer simply whether shareholders received entries in their accounts.
It is whether the aggregate beneficial-owner positions recorded by the broker-dealers reconcile, share for share, with the shares registered to those firms at the transfer agent.
The Reconciliation Question
How many Next Bridge shares are credited to customers at each broker — and do those totals reconcile, share for share, with the corresponding bulk certificates registered at Equiniti?
Evidence Assessment
The July 28, 2026 Next Bridge disclosure materially advances the MMTLP share-reconciliation record by providing broker-level registration data from the company’s transfer agent and by stating that those registered quantities do not accurately reflect the shares credited to customers within several brokerage firms.
The current public record, however, does not yet provide a complete, independently verifiable broker-by-broker comparison between the Equiniti registration totals and the aggregate positions reflected in customer accounts.
The unresolved issue is therefore specific and measurable:
Do the aggregate beneficial-owner positions maintained by each broker-dealer reconcile exactly with the shares registered to that firm at Equiniti?
Until that comparison is publicly produced or independently verified, the reconciliation remains incomplete.
PSD-012 — Next Bridge Regulatory Outreach Regarding Alleged Unauthorized Shares
Source
Next Bridge Hydrocarbons, Inc.
Date Issued: August 25, 2026
Primary Source: Next Bridge Hydrocarbons — Provides Update on Continued Efforts to Engage Regulators
Document Summary
On August 25, 2026, Next Bridge Hydrocarbons disclosed additional efforts by Chairman and CEO Greg McCabe to engage directly with the Securities and Exchange Commission and FINRA regarding what the company describes as evidence of unauthorized Next Bridge shares being created by U.S. broker-dealers.
According to Next Bridge, McCabe wrote on August 7, 2026 to David Woodcock, the newly appointed Director of the SEC’s Division of Enforcement, requesting a meeting to present what the company characterized as clear evidence of unauthorized Next Bridge shares being created by U.S. broker-dealers.
McCabe requested a response by August 14.
Next Bridge stated that it received no response and that no meeting with the SEC was forthcoming.
The company further disclosed that on August 14, McCabe wrote to Robert Colby of FINRA, provided the SEC correspondence, and again requested an opportunity to discuss the company’s concerns.
Next Bridge emphasized that the broker-dealers at issue operate within FINRA’s regulatory jurisdiction.
According to the August 25 disclosure, that outreach likewise had not resulted in a response or scheduled meeting.
Why This Document Matters
This disclosure represents an important escalation in Next Bridge’s continuing effort to obtain regulatory examination of the MMTLP share-reconciliation issue.
The significance lies not merely in the fact that Next Bridge contacted regulators.
The company says it sought direct access to the SEC’s Division of Enforcement and FINRA for the express purpose of presenting evidence it believes demonstrates the creation of unauthorized shares by regulated U.S. broker-dealers.
That distinction matters.
The July 28 disclosure identified the underlying reconciliation problem: Next Bridge said broker-level quantities registered at Equiniti did not accurately reflect shares credited to customers at several brokerage firms.
The August 25 disclosure describes what the company subsequently attempted to do with that information.
The evidentiary progression is therefore becoming increasingly clear:
Share distribution → broker-level registration data → alleged reconciliation discrepancies → SEC Enforcement outreach → FINRA outreach → reported absence of a meeting or response.
The Regulatory Question
If an issuer believes it possesses evidence that regulated broker-dealers have credited customer accounts with shares that cannot be reconciled with the shares registered to those firms at the transfer agent, an important question follows:
Who examines the underlying broker records necessary to determine whether the shares reconcile?
That question goes directly to the unresolved issue at the center of this Special Report.
Where is the reconciled share count?
Escalation Toward Legal Action
Next Bridge’s August 25 disclosure also marks another potentially significant development.
After reporting that its approaches to both the SEC and FINRA had not resulted in meetings, the company stated that it intends to explore all legal avenues available to it, while continuing to express a preference for a regulatory resolution.
That language represents a notable escalation.
The company is no longer describing only an effort to obtain regulatory engagement. It is publicly signaling that other legal mechanisms may be considered if that engagement does not occur.
Evidence Assessment
The August 25 disclosure does not independently establish that unauthorized shares were created by any broker-dealer. That remains an allegation made by Next Bridge and requires examination of the underlying records.
What the disclosure does establish is materially different:
Next Bridge has publicly stated that it believes it possesses evidence of unauthorized shares, has identified U.S. broker-dealers as the source of its concern, and says it attempted to present that evidence directly to both the SEC and FINRA.
As of the August 25 announcement, Next Bridge reported that neither effort had resulted in a response or meeting.
The underlying correspondence, broker-level records, customer-position totals, clearing records, and any subsequent regulatory communications therefore become increasingly important primary evidence.
If those records eventually become public or are produced through regulatory proceedings, litigation, subpoena, or discovery, they may permit the reconciliation question to be tested directly.
Evidence Status: Active Development — Regulatory outreach documented by the issuer; underlying allegations concerning unauthorized shares remain subject to independent verification.
The Report Continues
Future chapters will expand this Special Report as additional primary source documents, court filings, regulatory responses, and independently verified evidence become available. New chapters and Evidence Files will be added as they are completed.