that's where you're wrong, F1.. NO MATTER WHAT, ALL FILINGS MUST be filed and up-to-date. EVEN if the SEC or whomever just continues the circle jerk. At ANY TIME (especially if this gets in front of a judge), Megas should simply be able to say "I've always filed and done what I am legally obligated to do".
You start pulling the 'well, I'm not filing because you won't let me trade anyway' crap, it's just giving the DTC or whomever the ammunintion to say 'see, they didn't file".
NO EXCUSES. FILE.