Company confirmed RETC doesn´t qualify for Form 15 in April 8k, company knows the number of holders and in August 2019 RETC had over 1200 holders.
You see the interest, volume, over 4 billion outstanding shares, so it´s likely it doesn´t have suddenly fewer than 300 holders. Not difficult to see.
We all know there are no current filings and TA is gagged, so how could i show the current holders? But i guess we have all eyes and common sense.