I am sure the SEC has a file on Conman Clarke and Matt Dwyer now this "new" TGGI debt holder Matthew Hawrylak I am not sure about.
FINRA will be next IMO with 2 Broker Dealers holding the notes it would seem fitting and this old but recently disclosed asset and debt that has magically appeared on the TGGI cooked books should fall under FINRA Rule 6490.