Bell Buckle Holdings (BLLB)

[bradenhead]

I finally received a call back from Allen Flood, an attorney with the SEC - Office of Investor Education and Advocacy. I had emailed and messaged him regarding OTC Markets having not removed the Caveat Emptor rating from BLLB. We both pulled up BLLB on the OTC website. Together we went through everything on the respective News, Financials and Disclosure tabs. He felt everything was in order. He then went to edgar SEC filings page and searched BLLB. None of the financials disclosed on the OTC page have been filed with the SEC via the appropriate Form 10Q or Form 10K. Further, neither the Officer/Director disclosure nor the Attorney Letter with Respect to Current Information have been filed via SEC Form 8K. Mr. Flood suggested that they remain delinquent in their SEC filings and that is the likely reason OTC Markets has not removed the CE. Information is current...filings are not. In fact, the last SEC filing by BLLB was an 8K dated 9/4/2018.

Since I know of another company that recently had the Caveat Emptor designation removed, I looked them (NIHK) up on the OTC Markets page and saw that, sure enough, they had filed everything with the appropriate SEC forms as opposed to a simple OTC disclosure.

It appears public disclosure, in and of itself, is not enough for OTC markets to remove the CE while a ticker remains SEC delinquent.

We should all attempt to get Triage Microcap Advisors, LLC or Ms. Halvorson to address this to our collective satisfaction.