SEC GUIDE 7 HAS NOT BEEN UPDATED SINCE 1982, NO ACTION WAS TAKEN BY THE SEC following recommendations by SME //////// link https://www.sec.gov/comments/s7-29-07/s72907-8.pdf YOUR READING TO DEEP INTO REGULATIONS, IT'S ALL LEGIT RIGHT ON OTCMARKETS.COM billions does make sense and is more than likely in the ball park imo