_IF_ someone, unsolicited, were to offer Forrest cash for his old CMKM Diamonds shares, he would be within his rights to liquidate them in a private transaction.
IF, on the other hand, Forrest was in the habit of flipping CMKM Diamonds shares (or any other unregistered security) for a 150% mark-up and was constantly trying to line up buyers and sellers, then, yeah, the SEC would definitely have something to say about it.
And it probably wouldn't be very nice.
"The penny stock investor may be the most dangerous creature in the investment world, at least to himself.[...]His hypocrisy becomes most apparent when he then blames his losses on the greed of others." Robert C. Dugan, Director - JRM Capital