JL,
The power of mere words.
Pen.
Sword.
Carol, et al….
The first fact you need recognize being the specific wording involved...
'The Wells notices advised that the Commission Staff intends to recommend that the Commission bring civil injunctive actions against them alleging violations of the federal securities laws contained in Sections… .'
[ civil injunctive actions ]
'The recommended actions would seek, among other things, permanent injunctions and civil penalties.'
[ permanent injunctions and civil penalties ]
Noting that there is no specific mention of either civil fraud charges of any kind, type, sort nor civil charges otherwise. Only civil injunctive actions and penalties. Noting additionally that, historically, the Commission has only ever taken actual enforcement action in half of the instances in which its staff recommends that action be taken. The situation being as outlined. A matter of interpretation regarding the need for a registration statement(s). A matter of overly aggressive accounting practices otherwise. Nothing of a malicious fraud nature. Nothing of an ill-gotten gain nature. Of personal financial enrichment. No staff determination(s) calling for a far more tellingly worded notice. Just and simply potential civil injunctive actions relating as previously noted. Management potentially permanently enjoined, that is, from entertaining similar securities laws violations (if) in the future. Potential penalties levied otherwise.
Had a clear determination of actual maliciousness, of actual fraud, of actual ill-gotten gain/personal enrichment been made? The notice would have been worded accordingly.
None of it amounting to rocket science even slightly.
It being now in the hands of management and company accounting and legal. Whether to address securities laws interpretation issues, etc. or whether to proceed otherwise.
Interpretation issues based on…
'alleging violations of the federal securities laws'
[ alleging ]
The lack of actual proof.
As for America's Cleaning Company?
A matter of business as usual. Sales ever-mounting. Retail presence ever-expanding. New and novel marketing approaches. New and exciting products coming to market. New hirings. Etc.
As for FINRA and the regaining of the OTCBB quotation?
A matter of arbitration. Dispute settlement.
Our coming trading week to be more than a little interesting. Inclusive of the very realistic potential for a timely shareholder update. The investigative processes being now complete.
Setting the stage for the return to being OTCBB quoted. The opening of the PR and filing, etc. floodgates.
The end of the road for the company's greatest detractors.
The big picture fully emerged.
The undeniable.
That to, very much, smile about.
SJ...
I'll answer your question by way of posing a few questions of my own...
Does the current trading pattern represent an ideal covering opportunity?
Were it you?
Would you act?
Or no?
What, exactly, was the June blogging and nascent FUD routine all about?
What was the objective?
And there I'll leave it.
All the best to you and all others.
Peace indeed.
AI
