Super Hero Justice League Team America.

[Distracted Scientist]

I came across your post by chance. And, for your egotism, here is my response.

If you are going to quote SEC requirements, then you should verify the wording from the SEC first. The actual wording for your quote should have been:

"There are no Exchange Act reporting obligations... unless the company has more than $10 million in total assets AND more than 500 shareholders." (see: http://www.sec.gov/info/smallbus/qasbsec.htm )

They need to fulfill both requirements, rather than one or the other. This information concurs with all related SEC webpages, but was conveniently misworded at the link you provided.

While it is possible that they have more than 500 shareholders, it is statistically unlikely given the information available from both http://www.sharecounts.com and previous 15C2-11 documents. Most likely, there will not be a definitive answer for the number of shareholders until the new 15C2-11 is released in June. Until then, your certainty is only speculation.

And, for the record, financial information for PNMS is available here:
http://www.panamersa.com/financials

Best of luck!