$22,500 + $62,500 = $85,000 raised by CGFI. Never reported on any 8K. Obviously they can do this and DTC and reporting requirements are not a factor. At 45% discount, this would convert to about $188,000 worth of shares on day of conversion. Keep in mind they would only have to sell $85k worth to break even. They could let some amount ride and hope the company eventually succeeds. It seems to me, however, that the company could do a lot better by simply doing a public offering.
Again, there may still not be a final resolution of March 6 deadlines, hence no 8k required.