DD Support Board and Research Team

[jurisper]

I believe I've only read that they need to be current at the time they file the Form 15.

Dunno where I got the other notion from. This sets things out pretty clearly: http://www.sec.gov/interps/legal/cfslb18.htm

I'm usually tunnel-visioned on just a few pennyscams but even so I've noticed a bunch of companies with invalid Form 15 filings, just because they have a late filing notice hanging for a 10-Q/10-K before the Form 15 date.

A little computer program could pick out all these companies, and another one could generate suspension orders for all of them.

Somebody would have to sign all the orders, I guess, which would probably be the most time-consuming part of the exercise.