That is certainly plausible.
I've always posited that ARCA was ECAB via some non-traceable third party. Maybe they are PUMA, too? It might explain that goofy loan structure, too.
~$33M less ~$8.25M ~= $24.75M at a 10.5% rate.
When one includes the "discounted" money, the interest rate shoots up over 20%. Why not just give them a $25M at 20%? It looks better to say 10.5% but that's just lipstick.
However, we know an allowance of $5.5M for dilution was built-in. The worst thing you can do after a reverse split is dilute again, which is exactly what we've done. All parties involved knew this going in.
To not plan for this allowed dilution would've been criminal.
Perhaps SIAF is getting that discounted money but just indirectly? When dilution happens it creates other sellers. To soak up $5.5M in dilution you need more than $5.5M in capital. How much more? Maybe 50% more?
$5.5M times 1.5 = $8.25M