OMG. Did you read that post by Dark Lady and actually believe what she said? Thank You. I now understand a few things.
Let’s start this slowly.
1. FINRA has nothing to do with the investigation into SPNG so their “conclusion” without finding is ludicrous. FINRA has enforcement authority over registered members, not public issuers. The SEC has enforcement authority over public issuers. That is why you have never and will never see a FINRA enforcement action against a non-member public entity.
2. FINRA can’t be holding up a 15c-211 because none has ever been filed. The reason that SPNG is trading Gray Market is because they do not have adequate financial information filed with the SEC. For a 15c-211 to be filed, a market maker has to verify a level of accuracy to financial information. Notice Dark Lady never identified who it was (what Market Maker) submitted this form to FINRA for approval.
3. Massive NSS at $0.10. And where are they located where FINRA sees them and you don’t? For them to be at $0.10 they would have had to take place this summer or so. New rules make it much harder to hide these nasty buggers and certainly hide them for such long periods of time. Since the SEC FTD data hardly shows 1.5 Billion FTD’s, can you explain where they are hiding and why, with all this volume trading, they still don’t show up? You see, even a naked short will show up as a fail when the long that purchased that share goes out and sells long their position. How come NONE of these fails seem to surface?
4. Then we have the whole issue of management, investigations, and filings. If everything is done, why no 8K announcing success? Why no Press Release? Better still, why no 10’s filed if it is all over and the 10 was ready to go in September?
It is my understanding that Dark Lady became aware of all this insight by listening closely to Metter at the Noble Conference. Hidden between all else spoken was a superimposed message to the most talented of people and Dark Lady picked up the subtleties and has come here to report them out.
For those wishing to understand the 15c-211 process, SPNG has no say in it. They can try and go out and solicit a Market Maker to file one but they do not file one. A an application filed is between FINRA and the MM and FINRA would not even give the company a status on that filing. A 15c-211 is a market maker contract with FINRA and since issuers are not registered with FINRA they have no rights in this process.