This is definitely one of those things that may all be somewhere within the bounds of the rules, and the SEC will allow it, as long as you don't fuck it up. A "don't ask don't tell" kind of situation when firms tread into the grey area between the black and white of strict rules. My boss always used to say "We don't have many rules, just don't be the reason why we have to create a rule".

4.5) Because of their insane overuse of margin to ease onboarding, their depository obligations begin bleeding beyond their ability to triage, putting the accounts of both their investors and clients at risk.

5) RH then "margin calls" all of the people who had money transfers pending at the time of GME purchase (in order to reduce the overall risk profile of the robinhood brokerage and to scrape back as much money as possible to cover their depository obligations which they, goto 1, screwed up themselves by offering way too much margin to clients who didn't know they were getting margin (or what it even is))

Over the past two days, Robinhood royally fucked it up, beyond anyone's wildest fears. If they were Chase or BofA or someone, I'd say they're systemic and will get by to survive another day. They're not.

Robinhood is finished. If they somehow manage to meet their depository and net capital obligations over the next few trading days, and if they somehow manage to survive the large downturn in users the platform will experience after their actions this week, and if they survive the inevitable congressional hearing, they'll still have the SEC investigation to look forward to.