If the share structure could get cleaned up, and the shares could be audited, you could find a company to put into the shell, and find a market maker to submit 15c211 info to FINRA. Of course, you will have to pay them, even though they are not supposed to be paid for submitting the 15c211. However, they get around that, and if you want a MM to make the submission, you will have to pay. I believe you could also file a Form 10 w/ audit and then be OTCQB and fully reporting right out of the box. But would have to check on that. I'm working on cleaning up a de-registered shell now (yes, different), and if you have a legit business, you can relist. FINRA/SEC is more concerned about whether the new entity is legit, not the former shell. They are concerned that no additional people get scammed. From SEC perspective, those who were scammed are water under the bridge, they just don't want any additional people to get scammed.
The two biggest problems are whether the shares can be "audited" and whether you can get rid of all of the, IIRC, preferred shares that were handed out.
Expect the worst, hope for the best....
