jabberstox: I posted my questions, and my answer from the SEC. I certainly didn't make up the response (how smart would that be, make up or doctor an e-mail from an identified SEC attorney), and I know you are not suggesting that.
The SEC had a run in with National Stock Transfer Inc. a few years back, slapping them on the hands for helping another penny stock hide the facts about its stock sales. That's about the time National Stock Transfer Inc. stopped being a registered transfer agent.
All I can do is provide the info I got from the SEC. I can come to my own conclusions, you need to come to yours.