Well, whatever the REGDEX was referring to, the securities/debt sale could have happened no earlier than the middle of October. From the SEC's Form D:
"When To File: A notice must be filed no later than 15 days after the first sale of securities in the offering."
The form would also indicate to whom the securities or debt were sold. Also, if it was anything other than a 504, my personal interpretation is that they could have sold securities that were exempt from registration. Again, this is MY interpretation and may be totally incorrect.