RNVAs insider trading plan was filled in form S-1 12/30/22. After the "cooling off period" and a minor amendment, the insider trading plan went into effect 05/12/23. Sabby prospectus was then issued on 05/16/23 in accordance with insider trading plan. Took me awhile to figure it out, but the rules are in effect across all exchanges, so it is good to know, especially with OTCs.