Just look at the recent Petro America fraud, for one. Look at the SEC and DOJ position on reporting "reserves" when a full feasibility study is not completed. For non-reporting companies, it falls under the anti-fraud statutes. It is fraudulent to claim such "reserves".
In regards to the Hamilton interpretation, flip it around. It only reminds SEC reporting issuers they MUST use Industry Guide 7 (i.e., none of this NI 43-101 BS instead of Industry Guide 7, which has been popular among stock scams of late).