Replies to post #152951 on DD Support Board and Research Team

[janice shell]

I seriously don’t know why the SEC wouldn’t suspend VGTL on this transaction alone....

I have no idea, either. VGTL is an incredibly compromised shell. When Newbauer announced the deal, I wrote to FINRA about it. After all, it was FINRA that made it impossible for MIKP to get a new Form 211 processed. Presumably they had reasons for not wanting it to trade again.

But still, nothing happened. And that brings us to a related topic...

It seems clear that the SEC has changed its policy in connection with at least some trading suspensions. Look at the relevant page:

https://www.sec.gov/litigation/suspensions.shtml

It contains only five items. That's the fewest for any year-to-date since the agency began publishing the list. Granted, the most recent, from 10 May, covers 56 dormant shells. But there've been only four suspensions for cause, and NO suspensions of delinquent filers.

I'm ambivalent about the delinquent filers. Many have been delinquent for years, and don't currently trade much. Some presumably have longtime stuckholders who might want to sell if they knew revocation of registration was on the way.

But it does seem that generally, the SEC no longer feels that suspensions are a useful tool. That seems odd to me. Suspensions for cause are very useful. Oddly, the people who attended the SEC's roundtable on investor fraud last September seemed to favor the idea of MORE, not fewer, suspensions:

https://investorshub.advfn.com/boards/read_msg.aspx?message_id=148808604

So I'm left perplexed.

[integral]

It depends if the purchase was fair market valuation. But it appears it was an asset transfer from one owner to another, which is a criminal act.