I believe you are in part correct, however I believe FSPM was brought to light during the PHOT investigation and Halt. You can hardly ignore the fact the SEC investigates and Halts PHOT ( a FSPM Partner) then the Price of FSPM begins to falter and the Symbol gets a caveat Emptor sign and the PPS falters more in part due to FSPM failure to file timely.
Investors complain to the SEC who already likely have FSPM in the file on PHOT.
Now I suspect within a week these same investors you speak of will also have contacted one or more of the several Law Firms that have filed class actions against PHOT.
Regardless how Legit or not FSPM is the SEC saw reason to Halt it, now the Onus is on FSPM to either fight for investors and co-operate with the SEC in matters in question or not.
Whatever comes now will be a long time coming , there is no quick fix now
It is what it is.