Tuesday, November 26, 2019 6:07:22 AM
Read the requirements. Look at the form. They were NOT current at the time they filed the Form 15. You must be current to suspend filing obligations per sec rules.
https://www.sec.gov/interps/legal/cfslb18.htm
In order to rely on Rule 12h-3, the issuer:
must be current in its Exchange Act reporting obligations;3
3 More specifically, the issuer must have filed all reports required by Section 13(a) for the shorter of its most recent three fiscal years and the portion of its current year, or the period since it became subject to a Section 15(d) reporting obligation. See Rule 12h-3(a). In addition, if the issuer obtained an extension of time under Rule 12b-25 under the Exchange Act to file a required periodic report, it still would have to file the periodic report in question before availing itself of the suspension provided by Rule 12h-3. See Exchange Act Release No. 20263 at II.2.
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