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Re: janice shell post# 11098

Thursday, 02/13/2014 12:53:24 PM

Thursday, February 13, 2014 12:53:24 PM

Post# of 39962

So far, they haven't sold any of the shares they want to offer. Reg A offerings entail filing that 1-A, and having it deemed effective by the SEC. The SEC seems to be ignoring their request that it be deemed effective. There haven't even been any comment letters.

They can't sell anything until the 1-A is deemed effective, if it ever is.


@janice,

In your experience...

(1)
What is the typical turnaround time that the SEC usually takes in issuing a Notice of Effectiveness if it intended to do so? I am presuming that with the most recent Amendment 3 having been filed just last month (JAN-2014), that this must be an unusually long delay for you to opine that "the SEC must be ignoring their request"?

(2)
Is silence from the SEC typically meant to be construed as "denial"? Or would the SEC issue an official Notice either way to either make the offering effective or to reject the offering?

(3)
Is there typically a series (or at least one round) of comment letters for these types of offerings? In your opinion, can anything be read into the absence of any such comment letters from the SEC yet?

(4)
In your experience, does the SEC typically just "rubber stamp" these or do they get scrutinized and the SEC will often actually reject proposed offerings if they deem that such an offering in its current form would unreasonably and inequitably cause irreparable harm to current shareholders?

(5)
Overall, based upon what you have seen w/this name, combined with your experience overall in the markets, would you opine that the odds are more likely or less likely that the SEC would grant a Notice of Effectiveness for this proposed offering in its current form? Not going to quote you on anything, but just interested in your perspective based upon your years of experience in observing SEC behavior and trends in these matters.


OK, I'll turn off the Turkish prison interrogation lamp now. Time to hit CTRL-V: Thank you again, Janice!