That sounds right, but I would think that if you have a broker that has a wide OTCBB market, like Schwab or Herzog say, that they would request it for you. But there is no reason why RR just can't make it public anyway, it would be to his advantage, I don't know why he just doesn't put up the CMIHoldingsInc.com website?!?! Do me a favor and ask him, he should just put the form up on the website, along with some other info on the holdings, we'd be up to .003-.005 within a week.
imho, Jerome