eur, page-180

There have been new business arrangements at have been ratified by EUR since the first SEC lodgement and it would be expected that SEC would want further clarification after new contractual arrangements have been generated by the parties. That is just diligent practice.

Having never been involved in any SEC submission or any financial deal of this magnitude, I can only speculate. I have been involved in land grants, patent submissions and various other monetary grant proposals. What I have learnt from those processes is that the principals who sign off on submissions anticipate what the governing body may likely request and oversupply on detail to minimise the risk of time loss with follow up requests for information.

The SEC have guidelines that candidates must adhere to. SEC will likely assess what has been submitted. If there is a shortfall of information to satisfy all required criteria to get approval, the candidates will be given guidance formally and informally, of the areas in the criteria that have not been satisfied.

My question why did such experienced lawyers not foresee the SEC's questions and preempt that by holding off on submission until EUR and SZZL had supplied all relevant information and more to satisfy SEC. Isn't that the role - at least in part - of the lawyers to consult and guide this flow of information to the SEC in a suitable legal framework?

As always, I am happy to be corrected by people knowledgeable on matter that I raised.