West Coast Ventures Group Corp (fka WCVC)

[PennyHoper]

Hello Renee,

Thanks much for the detailed reply.

I will cut out my initial text which you answered (thanks again), and color your reply text 'red' (the first choice given to me by the interface):

The SEC Admin. Law Judges have always chosen to revoke an SEC Registered company's registration rather than suspend the stock for up to 12 months.

So, while leniency is legally allowed, the SEC Admin Law Judges always go for the harshest penalty, to teach offenders before them a lesson in the strongest possible terms. Is that correct?

[If so, it does make me wonder why the Order says mere suspension is a possibility.]

A company has only 2 choices: respectfully accept the A.L.J. revoking the company's stock registration(s) which would buy some good will IF the company decides to re-register with the SEC with a new FORM 10, or wait until the A.L.J. forcefully revokes the company's stock registration which puts more workload on the A.L.J.....bad karma IMO.

So a company only has two choices by history -- of how judges always treat them -- not by what the 'letter of the law' actually says and allows. Again, is that correct?

Note: I'm not saying companies should not respect the SEC which they have subjected themselves to, nor that WCVC shouldn't be called to account for its failure to file for over a year; I'm only saying that the actual wording of the law (in the Order) seems to allow for more leniency than has ever been granted by any judge, ever (as I take your word for it).

Do agree with me on this technicality, even if it has never been given any real world merit before any SEC Admin Judge?

Suspensions and Admin. Proceedings are the charges, whereas revocation is the punishment that occurs when the A.L.J. renders a verdict.

Hm ... "suspension" still sounds like a punishment to me, rather than a charge, given that the Order says it can be 'up to 12 months' (which implies it can be for a lesser term). With wording like that, how can it be a charge?

[Aside: English is my only language, but this stuff makes me feel the need to have Investopeia grafted onto one brain lobe, and whatever the investors' equivalent of Black's Law Dictionary is on the other lobe.]

Thanks for the summary of what happened "Prior to Sept 27th, 2021."

After Sept. 27th, 2021 the SEC implemented Amended Rule 15c2-11 where companies lost Market Maker quotations if a company's disclosures were not current and adequate. This applied to SEC Registered stocks that were severely delinquent in filing Financials to EDGAR or to Alternative Reporting (ie., not registered with the SEC) that had no current or adequate disclosures to OTC Markets. The Amended Rule 15c2-11 meant that the SEC no longer needed to suspend SEC Registered stocks that were severely delinquent in filing Financials because those stocks lost Market Maker quotations on either the Grey Market or the very deceptive Expert Market.....an OTC Markets invention that the SEC DOES NOT APPROVE.

So, the SEC did not need to suspend WCVC or any other delinquent SEC Registered stock because those stocks had already lost Market Maker quotations under the Amended Rule 15c2-11. The SEC only needed to file an Admin. Proceeding to revoke the company's stock registration(s).

I agree that stocks on the Expert Market don't "need" to be suspended, but a) they can still be traded by a certain class of 'experts,' and b) those stocks which were demoted to the Expert Market from OTC's Pink market for lack of up-to-date filings were so demoted with the full knowledge -- if not outright permission -- of the SEC.

You write about the Expert Market that it is "an OTC Markets invention that the SEC DOES NOT APPROVE," and I will conceded that the SEC may not be thrilled about it, but I poked around the interwebs today and found 33-10842.pdf by the SEC -- see:

https://www.findknowdo.com/news/09/17/2020/sec-adopts-additional-requirements-publish-quotations-otc-securities?utm_source=Mondaq&utm_medium=syndication&utm_campaign=LinkedIn-integration

and the link under the word "adopted" in the opening sentence.

Since that document is only 297 pages long, I didn't have quite enough time to read the whole thing word for word and thoroughly digest it all. But I cheated and did a key-word search on "expert market," and found a number of references that suggest that not only does the SEC not vigorously hate its existence and the very idea of it, but that the SEC, itself, identified at least one set of circumstances that the expert market's existence would serve a beneficial purpose for:

The Commission believes that, under certain conditions and circumstances, it could be beneficial to establish an “expert market” that would enhance liquidity for sophisticated or professional investors in grey market securities, as well as for small companies seeking growth opportunities that might prefer to be quoted in a market limited to such persons. [p.76]

Footnote 646 on p.221 also seems to confirm for me something I recall reading (but didn't preserve a link to) that the Expert Market pre-existed the 'day of infamy' when WCVC and stocks of its ilk were all demoted to the Expert Market; and the language of the footnote doesn't appear to condemn the preexisting purpose for it that was described.

The SEC will still suspend a stock for fraud and other Securities violations, eg., INSD.

And well it should.

Again, I didn't have time to read, let alone thoroughly digest, that whole document, but I did read what seemed to me to be a handful of scenarios proposed by the SEC itself that would justify allowing certain securities to trade without public documentation. I'm not saying WCVC falls under any of those scenarios, but only that not making financial status public is not always synonymous with fraud.

Do you know whether any stocks in WCVC's position have tried to assert a defense of 'COVID19 has nearly killed us already, so we didn't have the resources to file'? I'll bet that is their defense, or an element of it.

Thanks again for taking the time to reply, both already and in the future (if you think it's worth it).