It is false that 100% were revoked, as E-Smart was revoked for delinquent filings and then won / decision reversed on appeal. Maranda Fritz was attorney for E-Smart.
What is accurate enforcement recommends revocation everytime. An Inspector General should do a forensic examination as there are companies who have not filed for 5+ year periods. Very sloppy of the SEC.
100% would trigger review of regulation as does not result in due process if result is predetermined.