Replies to post #11878 on Strategic Global Investments, Inc. (STBV)

[janice shell]

What is the typical turnaround time that the SEC usually takes in issuing a Notice of Effectiveness if it intended to do so? I am presuming that with the most recent Amendment 3 having been filed just last month (JAN-2014), that this must be an unusually long delay for you to opine that "the SEC must be ignoring their request"?

I missed it the first night I looked at the filings. The SEC has indeed commented on the 1-A--or a 1-A--in January through March 2013.

http://www.sec.gov/cgi-bin/browse-edgar?company=strategic+global+investments&owner=exclude&action=getcompany

The company replied, and made changes to the filing. In its last letter from March 2013, STBV's attorney requested acceleration, which meant that he believed the comment process was over, or nearly so.

And then, oddly enough, two new 1-As were filed. The second has by now been amended three times. There have been no SEC comment letters, or, if there are any, they haven't yet been loaded onto Edgar.

Reg A offerings are pretty rare, so I have no idea what the average turnaround time is. Theoretically, though, the SEC can continue to request amendments until it feel the issuer has the 1-A right.

Is there typically a series (or at least one round) of comment letters for these types of offerings? In your opinion, can anything be read into the absence of any such comment letters from the SEC yet?

Comment letters from the SEC usually aren't posted until the matter--whatever it may be--has been resolved one way or another. So there could be current comments that resulted in the three current amendments, but we can't see them.

In your experience, does the SEC typically just "rubber stamp" these or do they get scrutinized and the SEC will often actually reject proposed offerings if they deem that such an offering in its current form would unreasonably and inequitably cause irreparable harm to current shareholders?

They almost never rubber-stamp these things. But as I said before, their job isn't to make judgments about the merits of the company's business plan, or of the offering. It's to make sure the form of the filing is correct, and that all the required information is included.

It's rare for the SEC to fail to deem, say, S-1s effective. They can invoke a stop order, but that's quite unusual. Sometimes when the letters keep coming and coming, the company gives up. Those are known as "bedbug letters".