Element Global Inc (ELGL)

[janice shell]

Yes, if a promoter is promoting a company, in email blasts, or with reports on his website or whatever, he's supposed to disclose the amount and kind of his remuneration. Did he get stock? Did he get cash? Did he get both?

The SEC insists that they must also identify the payor. A year or two ago, a couple of promoters pointed out in a pleading in an SEC suit brought against them that 17(b) doesn't require that. I don't know how it turned out. But my own reading of the section is that it doesn't, though it should.