Not so fast. Paragraph 20 of the SEC Cease and Desist order reads as follows:
That will still take some doing to be fully compliant given some of the deals that LP gave herself. One case immediately comes to mind that is arguably questionable. The D1 and D2 warrants that NWBO issued to LP in March 2018 were on much better terms to herself than the D2 warrants issued some 2 1/2 months earlier to retail investors, while no substantial change in the company prospects or financial position happened during that time to explain the much more favorable terms LP gave herself!
LP gave herself D1 warrants with a 22 cent exercise price and 2 year term, and D2 warrants with a five year term at 30 cent exercise price. Whereas some 2 1/2 months earlier she granted the worst of the above terms to retail investors in their D2 warrants with only only a 2 year term but the higher 30 cent exercise price - the worst combination of terms in both the warrants LP granted herself with no apparent rationale behind the better deal she gave herself!