Phoenix Associates Land Syndicate (fka PBLSQ)

[pnew122]

Filing investigation findings.
I want to start by saying the following data was obtained by e-mail. I have no links, and I will not post the company's name. I will however, tell you the type of company it is. Now if any of you want to do your own investigation, you're welcome to do as I did, and do some due diligence. And finally, take this for what it is worth. I'm not saying if it's true or false, just posting the information I have found. The company got this information from, was a pharmaceutical company.

Here was the original message I sent.
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Hi, I was curious if you could help. Years ago your company went
from a pink sheet to a filing OTC stock. Can you tell me about how long it
took to get the paperwork together "before" you were able to submit to the
SEC? I own a pink sheet company and trying to get a time line. Thanks
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Dear Paul:

We traded on the Pink Sheets from 9/10/99 through 5/4/00 and began trading
on the OTCBB on 5/5/00. Hope this helps.
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Hi,

Thanks for the quick response. I should have worded it differently I think. Can
you tell me how long it took your company to get all the paperwork together to
submit to the SEC? The company I own has been processing the paperwork for
several months now. It does have multiple divisions which I'm sure will
complicate the matter, but was trying to find some sort of average time frame
for all the data together for submission to the SEC. Thanks in advance.
==============================================================
Hi Paul:

I'm not an SEC attorney, so with all the appropriate caveats attached...

The Company needs to file a Form 10 or Form 10-SB (if it qualifies as a
Small Business). Likely, the SEC will have comments and it takes them 30
days to issue the first comment letter from the date of filing. Your
company must reply to these comments within a certain number of days.

I'm going to guess a few months to write the Form 10 or 10-SB, then you wait
to hear comments from the SEC, then you respond to the SEC comments, then
you wait to hear from the SEC again, then you get have follow-up comments
from the SEC, then you respond again, then hopefully they accept the filing.
I'm going to say in the ballpark of 4 - 8 months, depending on how quickly
the company works and how many comments you get. Just a ballpark though.

Hope this helps,
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That is exactly what I was looking for. It feels like pulling teeth to get
information like this for some reason. I did have just one more question if
you don't mind (promise). Was your company able to continue business as
usual and put out PR's and the like? The reason I ask is I have found some
information that suggests there is a "quiet" period. Did your company have a
time like this?

Thanks very much for all to this point.

Paul New
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Hi Paul:

I don't believe so. It is my understanding that a "quiet" period would
only apply if a registration statement under the 33 Act is filed to sell
securities -- as opposed to a registration statement under the 34 Act, like
the Form 10. But, I am not a securities lawyer so you will want to confirm
this with your securities counsel.

Good luck,
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Thanks for everything. I really appreciate the time you have spent on my
questions. I wish you and your company much success.

Paul New