Digital Brand Media and Marketing Group Inc (DBMM)

[Jetmek_03052]

No.

The term "Super 10-K" is a slang name used for the filing of a Comprehensive Filing.

Note the term "Comprehensive". Its definition is:
"Including or dealing with all or nearly all elements or aspects of something".

In THIS case, it is ALL the material information contained in the delinquent filing periods.

While the SEC DIv of Corp FIn's does not require the complete reposting of the missing 10Q's in a filing period, it DOES specify that any MATERIAL INFORMATION from those delinquent 10Q's be included in the comprehensive filing.

https://www.sec.gov/corpfin/cf-manual/topic-1

"1320.4 Delinquent Filers

(Last updated: 8/25/2015)

Generally, the Division of Corporation Finance will not issue comments asking a delinquent registrant to file separately all of its delinquent filings if the registrant files a comprehensive annual report on Form 10-K that includes all material information that would have been included in those filings.

The Division’s decision not to seek the filing of additional reports when a registrant files a comprehensive annual report does not absolve a registrant from any liability under the Exchange Act for failing to file all required reports and would not foreclose enforcement action for the registrant’s filing delinquencies."


The Div of Corp FIn's has stipulated that delinquent 10Q numbers be included in a Comprehensive Filing. The filing rules state that requirement. Foelak can't just wave her magic wand and make that regulation go away!