Official Trial Completion Date: (per August 19th, 2020 PR) Probably happened a few days prior to PR.
All we know of the actual primary completion date is that it was after Dec '16 and before mid July '20 (the PR that said all information from the sites was in hand).
The date is not the date when they have all the data. It is the date of the last patient evaluation in the data used for the primary analysis.
It is far from clear the 12 month rule applies. If the primary completion date was prior to Jan 18, 2017 it does not. If NWBO will be planning to file a BLA it dose not apply.
And the same law (42 CFR Part 11) also required NWBO to update the actual patient counts, completion dates and endpoints long ago. So not like LP cares about violating those laws. She is a lawyer and knows very well how to play the game.