Your submission missed the most important point of the rules you link to, that being that CGFIA is operating within the regulations of the SEC. If an investor is not satisfied with the rules governing these smaller companies, then it is their choice to not invest in them.
If the SEC does not require a company to file a certain form, or deems a different form sufficient for its purposes, why would they even consider doing other than what is required?
Don't take my word for it, Do your own research! Then you will know it's true!