The SEC changed its policy regarding overdue filin

The SEC changed its policy regarding overdue filings in September 2020. The way the government works when it changes its policies—particularly policies regarding enforcement—is to slam a handful of violators and make an example of them. It cares only about the headlines and what message the headlines sends to the business community. That is what it is ding with QTMM and the others. Nothing more. IMO, QTMM misread the SEC and thought making an effort and a showing of good faith would earn them some goodwill. A year ago, they might have been right. But that was then. This is now. If they have hired the right attorneys, then the attorneys will have a relationship with the regulators and will help QTMM position itself so that its story serves as a valuable precedent for the SEC about what does and does not fly under the new policy. If QTMM does the right thing and delivers, and does not play the “one more chance” or “this time we mean it” game, then the SEC can use QTMM as an example to send a message to the business community about what it takes to remedy these violations under the new framework. If Pasaca is committed, I’m pretty sure things will be done right, the SEC will be able to spin QTMM rehabilitating its filing delinquencies as a win for the SEC, and everything will work out.