GERS... But not criminal if you are broke and under severe Business stresses! I doubt very much if the SEC would use that term with Penny Stock Co's and Ceo's who have always paid attention to SEC rules and regulations in the past, but have undergone severe Business stresses and couldn't do as the SEC had asked of them for a period of time?
Yes notices were sent by the SEC, and responses most likely given as to why they did what they did? And believe me, GERS has much proof in the way of paperwork to justify their absent filings for the past 2+ years or so?