LOL Pat, I know you enjoy playing the devil's advocate, but now you not being logical, imho.
Maybe, maybe not. If I recall correctly, on the 15-211c the MM has to sign off with their backing of the most recent SEC filings by the company. I see nothing submitted in EDGAR under either Bankcorp or BCIT.
I may be recalling the rules for the 15-211 incorrectly, but I don't think so.