To me it’s a gray area. If they announce the ide submittal the share price will more than likely go up so it would affect the share price but only temporarily. Announce approval of ide the price will go up and will also maintain a higher price.
So announcing the submittal the price is only temporary affected.
I myself think the doc would be a complete idiot if he didn’t announce submittal.
This is definitely a SEC question. According to them I believe you have to announce anything that will substantially change the outcome of the share price.
They didn’t announce that they submitted for the BDD.
In my opinion no they would not have to announce the submittal