FINRA Rule 12206
Six-year eligibility rule. No claim is eligible where six years have elapsed from the occurrence or event giving rise to the claim.
Rule text. Selling-away and unsuitable-recommendation clocks are often argued from purchase. The 2024 freeze is a later date.
Why it shows up here: 4ANDJ Form D first sale 28 Oct 2021 → conservative line 28 Oct 2027. Vintage first sale 12 Apr 2022 → ~12 Apr 2028. Actual subscription dates, not Form D dates, are the ones that matter. Occurrence-date arguments (freeze, webinar misstatements, 2026 votes) can be made. Filing a regulatory complaint does not stop 12206.