In regards to the disclosure issues raised by 1mandband ( who has put in a lot of time presenting concrete support for his view) I believe even those on the "supporter" side of the company should be concerned.
The company faces several challenges ranging from permits to financing.I believe also the way they promote themselves doesnt help them build credibility in the market place. Some can believe management has the ability to navigate through the permitting and financing challenges. However the disclosure issues are clear, and once this company on radar sceen of SEC engineering office, there will be no way to avoid them.
Perhaps it is not appeciated what happens when SEC issues a comment letter. When they do a company has usually a fairly fixed deadline to respond. Companies retain legal counsel to help draft response, and usually unless they can convince SEC their filing was correct, they end up having to issue retractions and re-satements. The alternative if they refuse to agree with SEC can be enforcement action etc. The comment letters are often posted by the SEC with the company's filings ( previously this wasnt this common). 1mandband's quotes from several comment letters were typical of comments a junior mining company can receive. The issuance of a comment leter, response, response to response , etc can go on for months , hence can get quite expensive.
I have re-read the posts and there is nothing I have seen posted by anyone that indicates that the thrust of 1mandband's comments is not correct.I have no idea whether SEC is or isnt investigating the compay. If they were they would probably start with the 144 filings. However in my opinion there is no doubt the SEC engineering office would require a whole series of rather comprehensive retractions and re-statements of their 10k reports at a minimum.Better for company to do this pro-actively before that happens , or contact the SEC themselves and claim ignorance and inexperience as an excuse.
I consider myself open-minded, but reviewing 1mandbands comments, and responses to his comments, I seen nothing that indicates this company is following general SEC gudelines in regarsd to its mining activities. Maybe it is time for supporters to let CFO know the same and he will be responsible for this situation.
AI
