Digital Brand Media and Marketing Group Inc (DBMM)

[Poo28]

No Company has ever been suspended —-ever for delayed filings. NEVER. 


So revoke the 2-17% or 110 delinquent filings brought as new   annual administrative proceedings as if it was a law passed by Congress? In order to revoke all, there would have to be a law. That was never the intent of the regulation as stated by Company’s Counsel . Read the brief. 


That is NOT due process, and the Commission has a public policy role as Judge Foelak described in her judicial discretion. A legal foundation and building block.Perhaps clarity is required as to policy intended, and the practices allowed, as is done with many agencies. Test of Policy vs: practice is government role. 


Enforcement overreach is a problem and has been called out in many cases of the other 700+ OTHER, VERY SERIOUS cases annually brought by Enforcement. Check it out in Google —public info. I’ll post it myself later.


It is ludicrous to infer that when a Company proves and documents to the satisfaction of the sitting Judge that mitigating circumstances existed, that dismissal is Not the logical choice.


DBMM proved the facts in evidence. And the 4th Gateway test in delayed filings is the Company demonstrates its compliance going forward , with no recidivism. DBMM has done that and filed on time or early since the Super 10-K was filed on May 31, 2018.


https://www.sec.gov/files/2021-238-addendum.pdf


Stay Tuned with the facts