Friday, July 29, 2011 10:22:27 PM
In regards to SEC release # 33-9142...the release covered rule changes and amendments made by the SEC specific to section 404(c).
404(c) provides exemption from section 404(b).
my take...indeed Expo Holdings is exempt from section 404(c)...
So yes....Expo Holdings is exempt from requiring it's independent accounting firm to prepare an attestation report in annual filings.....as a matter of fact Expo's independent Accountant makes it quite clear that in no way shape or form are they attesting to anything....they state that they are relying 100% on managements representations only. Expo's accountant expresses NO OPINION regarding Expo's Internal controls....
But...in my opinion....SEC release# 33-9142 does not offer EXPH a get out of jail free exemption across the board.....
As for The original advisors,consultants and accountant... The consultant knows what he is doing although I do find it interesting that he demoted himself to shareholder status of Gaurdian Registrar and transfer...perhaps the cozy relationship was raising eyebrows..or maybe it was a proactive step.... anyway....the accountant has been disgraced due to what was ruled as incompetence and out of the picture...the advisor/consultant in my opinion set things up with himself in mind from a legal standpoint... meaning that JD and Glenn are on their own now in regards to shareholder loans/advances....false and misleading Pr's and their personal holdings ...not to mention the land and building 'sale' along with the creation of Wilkes Holdings.
The original steps of the R/M more than likely were technically "legal"...however ..the "consultant" is also an Accountant yet he chose someone else to *perform* and sign off on the actual audit...odd....the question today is....Have JD and Glenn crossed the line?
Pink Sheets...where failing private companies come to die.
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