I believe it was changed to 500 recently.
It's kind of known as the "Google" rule. It's always been 300 for companies already trading with registered shares.
The 500/$10 Million asset rule is for private companies who were circumventing filing requirements.
You are supposed to file once you become reporting...and maintain filing.
By the way, if you are really looking for a loophole, drop your 15g theory and realize all Tom needs to do is have an attorney request an extension. Under S.E.C. rules, companies facing revocation may ask for an extension. The "catch" is the company must show proof of being in the process of having past filings prepared.
The S.E.C. will ask for the name of the company preparing the missing financials and will call that company periodically for updates.
Urban tried to exploit this loophole but Leslie Hakala found out Urban had no auditor.
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