We heard you and have read the 90 day "lapse" rule.
Agree on your post except that the 90 day lapse rule should not apply since we are disclosing information to FINRA. According to an earlier post, FINRA will not close the request while they are reviewing the submitted information.
Since the company responded to FINRA's requests and submitted the SEC filings on August 9, 2017, the 90 day lapse rule would not come into play if FINRA is still in the review process IMO. I don't believe FINRA will lapse a company in the exchange process between comment letters from FINRA and information submissions by the company (FINRA could take 90 days to respond if they wanted, no shot clock).
We have submitted all that FINRA currently has requested according to RO conversation with some on this board. .
I don't think they would lapse a company's request if FINRA took longer than 90 days to review (which can happen), even if no additional information was requested. That would be a low blow by FINRA. "Sorry, we took 91 days to review your paperwork, please refile per the 90 day lapse rule."
I don't know why they would have to refile, unless we have passed the effective date of the corporate actions now.
The date out there of Aug 25th is the date that finra set for Dolv to have all their data into them. It would be like April 15th for taxes. So that is all the date is. Finra could take as long as they want.
Finra is tougher on Dolv because of all the SCAMs out there according to Richard.We have presented all that finra wants. He said they keep asking Mr Wang how many employees do you have....been an issue.
Here is an excerpt about the phone call with the FINRA Ombudsman. I couldn't find the previous post at the moment.
There was a phone call to the Finra Ombudsman as to general process questions. He said if an issuer provides the info they request, say on the 89th day, they won't lapse the application till they review the information. And he said if they have it prior, they will make every effort to review the info prior.But if it's more complex, they won't lapse it while they're reviewing the info. The only reason they would lapse the application on the 90th day, is if the company failed to respond. He also said if an issuer had to refile, that they do go to the back of the que, however he said our que isn't that long and most of the info would have already been reviewed. So, no more then a few weeks if an issuer refiled as long as nothing new has arisen or happened since the last application