Mastaflash, Yes but the question is who enforces the rules, unless SEC can see some type of fine or engorgement they can levie, they won't enforce or follow their own rules.
That old grandfather clause, that anyone selling shares before 2005 did not need to cover.
That most certainly tells us where SEC is coming from.
Sure, they finally rescinded the grandfather clause after many comment periods and hearings, to string it out as long as possible, giving those NSS lots of time to get legal, some did some didn't.
Chain of command
Cartel:12 bankers Foreign and domestic
Central Bank (controls or is part of conglomerate (brokers MM'S)
Federal Reserve (sometimes over site by Congress)
subsidiaries DTCC
Watch dog
SEC
Primary purpose too keep companies legal to collect fines, and investigate wrong doing, if criminal they turn over to the DOJ
The SEC has little to do with those above them in the chain of command.IMO FWIW