Gary, I think you are wrong and here's why. In most cases a form D is required by the SEC 15 days after funding. Now I think we can agree OWCP has indeed received funding and is why Zeevi is on board heading up the MM study. In rare occasions a company may talk to lawyers to delay announcements of funding because the person/company doing the funding wants a competitive edge. The only people I think would care about that is big pharma, in my opinion.
https://techcrunch.com/2017/09/23/how-to-anno...ing-round/