I'm confused. Did the SEC ask GNBT to register the

I'm confused. Did the SEC ask GNBT to register these shares in a Form D? If not, they missed the deadline of 15 days after the date of first sale to file it.

They attempted to register these securities in an S-1 dated Aug 20. If there is an issue with the way they registered the securities, are they going to be subject to the penalties laid out in the Aug 7 8-K?

"Registration Rights

In connection with the Private Placement, the Company and the investors entered into a Registration Rights Agreement dated August 4, 2020 (the “Registration Rights Agreement”) providing for the registration for resale of the Securities (the “Registration Statement”) to be filed with the SEC on or prior to twelve (12) business days after the Effective Date. The Company has agreed to use its commercially reasonable best efforts to cause the Registration Statement to be declared effective as soon as possible, but in no event later than the earlier of the (x) seventy fifth (75th) day after the Effective Date and (y) fifth (5th) business day after the Company is notified by the SEC that the Registration Statement will not be reviewed. The Company shall also be required to register Securities not covered by the Registration Statement in accordance with the provisions of the Registration Rights Agreement. If the Company does not meet its filing or effectiveness deadlines or does not maintain its listing on the OTC QB, then, the Company must pay a cash amount to the Buyers equal to two percent (2.0%) of the aggregate Purchase Price for each missed deadline or maintenance failure and then again on successive dates until such filing or effectiveness is achieved or such failure is cured. In the event these payments are not timely made interest at a rate of to 1.5% per month on late payments shall accrue until such amounts are paid."