lol that's the part I don't get, how can it be legal to not disclose what is required in the publication?
so your telling me the sec told you it is ok to publish something without proper disclosure based on the idea of people have to come to the promoter and ask who the third party is?
Not saying i dont believe you, I just find that quite incredulous and I have not seen that in print anywhere the topic has been broached...have you? I would like to see that, I mean hey if you dont have to disclose and all you have to do is tell folks on the phone or email, that leaves a lot of room for trickery