". . . relating to the Company’s internal controls over financial reporting and the adequacy of certain disclosures made in the past."
The financial reporting issue is fairly common, especially with companies that have a limited number of employees. It is almost impossible to have effective separation of duties under the circumstances and I expect that LP and LG have to personally approve almost any material disclosure.
The other item seems to be an event that the company disclosed but in insufficient detail for the SEC's liking. I suspect that this relates to the underlying reason for the Phase III clinical hold. The fact that a hold was imposed has been revealed, but never the reason for doing so. The legal definition of materiality was set forth in a landmark Supreme Court case where it was ruled that "an omitted fact is material if there is a substantial likelihood that a reasonable shareholder would consider it important in deciding how to vote,"
While that case concerned a merger vote, the courts have applied the ruling to other cases concerning materiality. I think most shareholders of NWBO would consider disclosure of the reason(s) for the FDA clinical hold important, and that makes the omitted disclosure a material fact. What is less clear is the penalty the SEC could impose on the company. Worst case they could pull the company's registration, effectively making NWBO a private company that cannot be traded, or they could impose monetary fines on some of the individuals involved. A shareholder class action against a company that is almost broke is pretty much an empty threat because no good plaintiff's attorney is going to take the case on a contingency basis.