Hi Anvil,
As an SEC non-filer, MDMN is not subject to SEC Industry Guide 7. I had this recently confirmed in no uncertain terms by the SEC's Corporate Finance Division. Anyone disputing this can reach out to them as well. However, just because a company is not an SEC filer does not mean they are absolved from responsibility in what they say in their public releases, as they still fall under the anti-fraud provisions in Section 10(b)-5 of the Exchange Act. To further paraphrase what was told to me by the SEC representative, the company must be able to factually support the information they put out publicly...which seems rather obvious.