Replies to post #110338 on JB and ZJMY Holding Co (JBZY)

[Stock Farmer]

I see what you are saying.

The company has 90 days to "sufficiently respond" to FINRA's request for additional information. I would not think the 90 day "lapse" rule would apply with ZJMY, since they have adequately responded to FINRA, IMO. However, what dictates a sufficient response in FINRA's subjective mind is another matter.

After rereading the rule, FINRA may deem a response insufficient. It is crazy since, FINRA can take months to reply or comment back to the company after the company submits additional information.

(2) Lapsed Requests
Where a Requesting Party does not, in the reasonable determination of the Department, sufficiently respond to any request by the Department for additional information or documentation pursuant to paragraph (b)(3) above within 90 calendar days following such Department request, such party's request shall be deemed "lapsed" and be closed.

I understand the ball is in FINRA's court and they do not have a shot clock, unfortunately.

IMO, August 25 could be a date JB&ZJMY is striving for for their own reasons (maybe the company chosen Effective Date for the name and ticker change? the launch date of SUVs? date Ministry listing comes out?).

[Stock Farmer]

August 25, 2017 must be the "Effective Date" IMO.

Under FINRA Rule 6490 Processing of Company-Related Actions there is no time limit by what I can see other than the 90 day "lapse" rule.

FINRA Manual - Rule 6490

IMO, I believe ZJMY has avoided the FINRA 90 day "lapse" rule by adequately responding to FINRA's requests for more information by submitting the 10-K and 10-Qs. However, we can't be guaranteed FINRA won't request even more additional information.

IMO, The August 25 date must have been the "Effective Date" put on the FINRA Issuer Company-Related Action Notification Form submitted by ZJMY's representative.

From ShareHolder Letter

*The corporate name changes must be approved by FINRA before the Company can begin trading under the new name. This process has commenced and must be concluded before August 25, 2017. The Company has been required by FINRA to file historical Form 10-K for the year ending February 28, 2013, and three subsequent Forms 10-Q. To that end the Company has hired an auditor and believes that it should be able to conclude the process without the need for refiling of the FINRA Notification although there can be no assurance of that filing or otherwise complying with any other FINRA demands.

IMO, That could be why, according to the letter, it "must be concluded" by then, or the company would have to resubmit the FINRA Forms with a new Effective date and pay the $500 Voluntary Symbol Request Change fee since it is an "Other Company-Related Action". RO has confirmed this as stated in a recent post by Arataps.

Arataps post on RO response on the August 25th "deadline"

RO told me in an email that if FINRA doesn't approve the change by the 25th, the company will need to refile and pay an additional $500. While I'm sure they couldn't care less about $500, I do believe they will do everything in their power to get it done by the 25th deadline.

FINRA Manual - Rule 6490