What I know, is that a laymans pdf interpretations of interpretations version is/are not the regs, and the regs are not the law, they are simply codified regs based on bureaucrat interpretation of the interpreted intentions of the law, that only a Judge (the Supreme Court) has the Final say so as to if the Reg is even legal or not).
I have made a living correcting bureaucrat newbie inspectors miss interpretations of regs (in another sector, not the SEC) and I get my info from the actual regs, I suspect folks like Hun=bin do as well.
If there is back his firm would know how to find and use it.
I am not saying there is a back door, because I am not an SEC expert. But I not going to assume the opinion of a post I know has a known agenda is fact that you just agreed with me on:
I don't see how anyone could "game the system" to immediately jump from OTC to a major exchange unless they qualified for the one exemptionthat doesn't require a long wait - completing a successful underwritten offering that brings in at least $40 million.
Bingo, that is point, Real regs are riddled with exemptions and Loop holes and you just named one.
An SEC 1-A filing, tier II allows MILVD to raise up to $50 Mil dollars.