DGF has limited the number of loans and won't be considered a Dealer/Broker.
I can find only one case where the SEC filed a complaint about a toxic lender being a Dealer/Broker and that was John Fife and his many companies - I have been writing about Fife for years.
I suspect that there will be a settlement and a 3(a)(10) exemption clause - which will make all of the DGF shares free trading immediately.