Can anyone answer this for me?
What is the definition of a promoter in the SEC's eyes. Below is the definition but I don't under stand why the only two directors of SIGO are considered promoters.
From the S-1
"The foregoing persons are promoters as that term is defined in the rules and regulations promulgated under the Securities and Exchange Act of 1933.
T.J. Magallanes, Chairman, CEO, Director.
Valerie Baugher, President, CFO, Director"
SEC Definition of Promoter:
Promoters: The category of “promoter” is broad. Securities Act Rule 405 defines a promoter as any person—individual or legal entity—that either alone or with others, directly or indirectly takes initiative in founding the business or enterprise of the issuer, or, in connection with such founding or organization, directly or indirectly receives 10% or more of any class of issuer securities or 10% or more of the proceeds from the sale of any class of issuer securities (other than securities received solely as underwriting commissions or solely in exchange for property). The test considers activities “alone or together with others, directly or indirectly”; therefore, the result does not change if there are other legal entities (which may themselves be promoters) in the chain between that person and the issuer.
AI
