The downgrade was more severe than normal. Normal is to lower the tier from Current to Limited Information for filing failure (like 10-Q/K). The downgrade was straight to No Information. That generally doesn't happen for a full six months of no filings (including 8-K explanations), and I have carefully tracked prior OTC Markets changes to understand the new system.
Since there are as-filed questions on last 10-K from SEC, I'm guessing there is a real problem and coming SEC action. FINRA failing to grant actions was a futher tip-off to a problem.
