US Stem Cell Inc (USRM)

[Dragon Lady]

Dubb, I think one would be looking at a long, long, tough road trying to get the SEC to look at "trading improprieties" on a micro, nano cap OTC stock. One would have to lay out all the evidence for them- who's colluding, what firms, what dates and times it occurred, etc.

As you stated the SEC person on the phone said, the SEC's role seems to be more with regulating and looking at the companies themselves- aka the SEC filings, their accounting being correct, no false PR or running of what's commonly known as "pump n dumps", no internal company corruption, etc

Here is a link to SEC actions, you can see it's always against companies and almost always for lack of SEC filing, misuse of PR, false or misleading PR claims, false statements, accounting problems, implications of running the P&D and similar- read through um, it's quite an interesting read IMO. Almost all are OTC or "penny" stocks, every time:

http://www.sec.gov/litigation/suspensions.shtml

"trading" improprieties is probably more a FINRA and DTC (Depository Trust) type issue would be my guess- that's why they exist and are usually called "gate keepers". They monitor and "clear" all trades and settling of trades, make sure order flow "matches" and is legal, shares are registered and legal, etc. Not so much the SEC from my understanding. FINRA would be the broker regulators per my understanding. DTC makes sure the shares are legal, that order flow is on the up and up and more. DTC is a very big and secretive organization. $TRILLIONS in trades are processed all via DTC. Also, the company's (BHRT's) own Transfer Agent is supposed to be part of that chain per my understanding and is involved in being DTC compliant and all. The agent for BHRT shares is Continental Stock Transfer.

I think the stuff you're after is more DTC and FINRA related more than likely. Remember, not too far back- BHRT issued an 8-K that indicated that the DTC had "questions" about some shares being properly "eligible" or something like that. Here, here's the language and link to that 8-K (look up DTC chills or freezes as an example of what the DTC can do, similar to the SEC who they work with also)

http://www.sec.gov/Archives/edgar/data/1388319/000114544314000932/d31492.htm

" In addition, the Company has received a request from The Depository Trust Company (“DTC”) to confirm that shares of common stock deposited at DTC were eligible under the Rules and Procedures of DTC for deposit. The Company has responded to this request."