You are not close to being accurate - for OTCQB you don't have to be a SEC filer as of the first of May.
For edification let me help:
"Definitions
Capitalized terms used in these OTCQB Standards shall have the following meanings:
“Alternative Reporting Company” shall mean a Company incorporated in the U.S. that is not an SEC Reporting Company, Bank Reporting Company, Regulation A Reporting Company or International Reporting Company, and that makes disclosure available through the OTC Disclosure & News Service pursuant to the OTCQX and OTCQB Disclosure Guidelines."
Sorry to burst your bubble but the OTCQB - is just for pumping only and Form 15 or dark companies can now be on the OTCQB tier and it certainly isn't uplisting.