Getting one's financials audited by a PCAOB registered audit firm is VERY expensive. That is why most OTC PINKS will use an accountant and then get a signed attorney letter so as to meet with OTC PINK rules:
3. If financial reports are not audited by a PCAOB registered audit firm: • Submit a signed Attorney Letter Agreement (first two pages of the Attorney Letter Guidelines). • After following the appropriate procedures with a qualified attorney, upload an Attorney Letter complying with Attorney Letter Guidelines through your otciq.com account.