Chance are FINRA is questioning the number of shares that Joe wants to dividend out (2:5 of non restricted share count on 8/29/19) since there are more non restricted shares now with the CMF and Veneto sales. If I was FINRA, I would question how GNBT will get all the non restricted shareholders the dividend and not the quantity from 8/29/19, since buyers bought based on the filings to get the shares.
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Disclaimer: Of course, all of this is my opinion and you should not make any investment decisions based on my opinion. I have not received any non-public information.