They can lie about what ever they want. If they want to file a registration statement which will require audited financials, the SEC will not accept a 2011, 2012, and 2013 audited statements ending June 30, 2013. They would be stale. If they were to file a registration tomorrow, they would have to audit Q1 and Q2 of 2014 to go along with 2011, 2012, and 2013 to bring their audit within 132 days of the statement.
Contrary to belief that Qs are not audited, they usually are not, they are reviewed, they are audited incorporated in a FYE. But in the case of a registration, they need to be audited and current or the registration cannot be effective.
I agree with you, there is no audit, because they are not auditable. As I said with another issuer who recently got suspended, they promised audits, but I was advocating that they could not stand the test of share reconcilliation from inception. So then they decided to try to merge into a new shell just before suspension. I told them that was not going to work because the reconcilliation still has match up. Merging into a new entity does not make the issuances disappear.
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