BCIT was never required to be fully reporting, and isn't today. It was a voluntary filer, but no special treatment is given to voluntary filers it should be noted. The problem is that the revocation refers to an issue of stock, in this case common A stock. Had BCIT not been a voluntary filer, it would still be trading today on OTC. If SEC had processed form 15, we would be trading today ( this may prove to be a blessing in disguise ). As far as I can tell, BCIT could issue new shares under REG D, and obtain a symbol and trade on OTC. The only way to get the common A shares trading again, would be to re-register them with a form 10.
Now, as for that missing form 15, there must be a discussion about the # of SHs of record BCIT had at the time, which was around 81 as far as T/A record was concerned. However, SEC reserves the right to determine what constitutes a sh of record, and they like to include beneficial owners ( that's us ). If the brokers are unwilling or unable to provide that info to the T/A, as has apparently been the case, then of course they can't be counted. Under the circumstances, one can understand that, given that beneficial owners represent 300M pulse shares, when there was never more than 725K issued. More telling to me is that the form 15 was lost and not found, which I would think it would have been, had the sh #s exceeded 500, and given the SEC an iron clad reason the dump on BCIT. Had the form 15 be entered and effective as it should have been, BCIT could never have been revoked. It was in the best interests of the SEC and market participants, to revoke BCIT, but with a valid form 15 submission, there would have been no legal way to do it.
...for goodness sake lets have some fun watching these people squirm. - CH
