They are digging a deeper hole if they are not being forthright.
NWBO has many regulatory eyes watching them -- including, NWBO tells us themselves -- the SEC. So I'd hope they are not deliberately pulling a fast one. Can you imagine how messy that would be? Nah, I think Dr. Bosch does not believe they are going to get stymied by regulators (FDA, PEI, etc), nor do I think they would set themselves up to be stymied, particularly not with all the independent experts working on this.
They had more money to do this SAP right from the property flip profit at the turn of the year. Paid these big time independents up front to prepare the SAP, and now they are apparently at the cusp of SAP submission and hopefully soon thereafter, SAP "buy-in," imho.