I am not certain what you mean by first and second tiers:
The way that I read the new OTCQB policy, there is (1) a penny test, and (2) a schedule to roll out that penny test.
The rollout schedule applies differently to companies that are not listed as OTCQB as of April 30, 2014, and companies that are listed OTCQB as of April 30, 2014:
(a) new companies going onto OTCQB after April 30, 2014, must meet the penny test; but
(b) existing OTCQB companies face a rollout, which depends on when their fiscal year ends.
The earliest that an existing company must meet the penny test is July 31, 2014, and that applies only to existing OTCQC companies with fiscal years ending March 31, 2014. If an existing OTCQC company's fiscal year ends March 30, their compliance deadline in July 31, 2015:
So that single day (between March 30, 2014, and March 31, 2014) makes an entire year's worth of difference. SNEY is somewhere between those two boundaries, and its compliance deadline should be December 31, 2014 + 120 days (i.e., April 30, 2015).
I am an amateur at this, and it would be unwise to rely on my opinions without your own independent confirmation in consultation with an investment professional.
Register for free to join our community of investors and share your ideas. You will also get access to streaming quotes, interactive charts, trades, portfolio, live options flow and more tools.