The form 3 instructions say, and has been noted here many times: "(a)This form must be filed by the following persons (“reporting person”): (i) any director or officer of a bank with a class of equity securities registered pursuant to Section 12 of the Securities Exchange Act of 1934 (“Exchange Act”); (Note: Title is not determinative for purposes of determining “officer” status. See SEC Rule 16a-1(f) for the definition of “officer”);", etc. http://www.sec.gov/about/forms/form3data.pdf
The asset base and the shareholder count required filing of form 8-A ("FOR REGISTRATION OF CERTAIN CLASSES OF SECURITIES PURSUANT TO SECTION 12(b) OR (g) OF THE SECURITIES EXCHANGE ACT OF 1934"), which they did on 9/28.
The Form 3's that were filed, albeit about 10 days late, were based on the 8-A filing registering the company's shares under Section 12(g). We should expect to see additional filings from SM and RME, the latter for at least their Class B holdings.
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