Many former promoters could very well do that rose as the pay outs are a minimum 10% of recovered monies up to a maximum of 30% on all minimum $1M judgements. So it's going to be very lucrative to the whistle-blowers who dig into all the available due and expose provable scams and scammers.
Twitter has an unbelievable amount of non-disclosing promoters these days for example with many multiple id's I'm sure. And the majority of the time promoters are working for co.'s and/or penny company funders who need a liquid market to leak shares into...so it's not just the promoters the new rules are designed to go after. It's the co.'s designing BS PR/IR campaigns solely intended to bring buyers into their stock so that insiders can dump into the false story being perpetuated...or the penny funders not adhering to the governing laws when leaking shares into market from whatever funding instrument they're using.
So there's going to much more exposed over the next couple of years pertaining to the dirty shell players, less than reputable penny funders, snake penny company insiders involved in multiple shells, penny company promoters, straw men directors, shell and money laundering facilitators and less than reputable lawyers who for a price will sign off on illegally registered paper...and all those involved with or in possession of offshore accounts to hide their activities and/or hide their income from their respective countries tax man.
There's a reason the penny market on a whole has lost so much of its dollar volume liquidity over the past few years and it's mainly due to the fact that straw men directors get placed into public shells so that the facilitators behind the deals can cash out without ever making a viable growth model but instead just spinning a kool-aid story that will suck in the gambling masses.
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