Janice, I read what you wrote below but I don't think that will be the issue here because the "NEW" CEO knows SEC regulations inside and out as he deals with them on a regular basis, SO I AM TOLD and IMO of course.
"There was a case a few years back that to some extent illustrates this point. The company's prior management had sold the shell to someone new. Someone who had an actual business he intended to roll into it, or so he said. Six months or a year later, the SEC moved to revoke registration. The new CEO was taken entirely by surprise, presumably because he hadn't done his homework."
"He objected to the procedure on the grounds that he hadn't realized he needed to file, and that he was starting from scratch. The SEC was not sympathetic. They revoked anyway."