H-D International Holdings Group (HDIH)

[Stock Farmer]

I don't think there is a time limit in order to get the stop sign removed. It will obviously be in the company's best interest to get updated on all the required filings (financial statements) as soon as possible, especially if like the tweet mentioned, they are planning an APO.

Sorry for the long post, but it could be helpful to others.


An APO would require the company to be SEC compliant and that disclosure process would be followed.

Since TRKG is a pink, they don't have to be SEC compliant.

It appears a company can remove the stop sign at any point in time if they are willing to put in the work to become current, whether through the SEC or OTC Pink disclosure guidelines.

Note: If a company chooses to follow another reporting standard such as the International Reporting Standard or SEC Reporting Standard, it meets the Alternative Reporting Standard requirements. Pinks can choose to be SEC Reporting.

https://www.otcmarkets.com/marketplaces/otc-pink


TRKG may use the Alternative Report Standard to get Current first, and later become SEC compliant.

Pink Market Segments

OTC Markets Group further segments Pink companies based on the quantity and quality of information they provide to investors:

Current Information
Limited Information
No Information
Current Information

Companies categorized in this segment qualify through the Alternative Reporting Standard (ARS), by making filings publicly available through the OTC Disclosure & News Service pursuant to the Pink Basic Disclosure Guidelines. Companies that follow the International Reporting Standard, requiring the company be listed on a Qualifying Foreign Exchange with periodic disclosure filings, those meeting the SEC Reporting Standard or U.S. Bank Reporting Standard are also eligible.

The Current Information category is not a designation of quality or investment risk.

Initial Qualification pursuant to the Alternative Reporting Standard:
Subscribe to the OTC Disclosure & News Service on www.OTCIQ.com to publish your financial reports and material news.
Publish the required disclosure document in PDF Format (Do not scan your docs to create PDFs! Here's Why) and upload them via www.OTCIQ.com in the “Add Financial Report” section:
Annual Financial statements for the previous two fiscal years. If these reports are audited, please attach the audit letter. Each year’s Annual Financial statements should be posted separately under the report type “Annual Report” on www.OTCIQ.com
Any subsequent Quarterly Reports, since the most recent Annual Report, should be posted separtely under the report type “Quarterly Report”on www.OTCIQ.com
The most recent fiscal period end report should also include information in accordance with the Pink Basic Disclosure Guidelines
Financial reports must be prepared according to U.S. GAAP and must include a Balance Sheet, Income Statement, Statement of Cash Flows and Notes to Financial Statements, but are not required to be audited.

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 the Attorney Letter Guidelines through your www.OTCIQ.com account
Ongoing Disclosure Obligations:
For each Fiscal Quarter End, upload a Quarterly Report via www.OTCIQ.com within 45 days of the quarter end. (A separate quarterly report is not required for the 4th quarter.) The Quarterly Report should include:
Information in accordance with the Pink Basic Disclosure Guidelines
Quarterly financial statements (Balance Sheet, Income Statement, Statement of Cash Flows, Notes to Financial Statements). Financial reports must be prepared according to U.S. GAAP, but are not required to be audited
No Audit Letter or Attorney Letter is required
For each Fiscal Year End, upload an Annual Report within 90 days of the fiscal year end. The Annual Report should include:
Information in accordance with the Pink Basic Disclosure Guidelines
Annual financial statements (Balance Sheet, Income Statement, Statement of Cash Flows, Notes to Financial Statements, and Audit Letter, if the financial statements are audited). Financial reports must be prepared according to U.S. GAAP, but are not required to be audited
If the Annual financial statements are not audited by a PCAOB registered audit firm, upload an Attorney Letter via www.OTCIQ.com in compliance with the Attorney Letter Guidelines within 120 days of the fiscal year end.

Financial Report Timeline for Maintaining Current Information (FY 12/31 Filers)
Fiscal Period End Date Report Type - Due Date
12/31/2015 Annual Report - 3/30/2016
Attorney Letter - 4/29/2016
3/31/2016 Quarterly Report - 5/16/2016
6/30/2016 Quarterly Report - 8/15/2016
9/30/2016 Quarterly Report - 11/14/2016
12/31/2016 Annual Report - 3/31/2017
Attorney Letter - 5/01/2017
*Companies following the Alternative Reporting Standard to maintain Current Information can file a Notification of Late Filing for an extension of 5 calendar days to file a Quarterly Report and 15 calendar days to file an Annual Report.

http://www.otcmarkets.com/ajax/showFinancialReportById.pdf?id=136276

Qualifications for the OTC Pink - Limited Information Tier
OTC Markets Group Inc.
OTC Pink Basic Disclosure Guidelines (v1.1 April 25, 2013) Page 2 of 8
Companies that make the information described below publicly available within the prior 6 months qualify for the Limited Information {aka Yield Sign}
Tier.
1. Subscribe to the OTC Disclosure & News Service on www.OTCIQ.com to publish your financial reports and material news.
2. Create a Quarterly Report or Annual Report for a fiscal period ended within the previous 6 months, save it in PDF format and
upload it via www.OTCIQ.com. The Quarterly Report or Annual Report includes:
? Balance Sheet, Income Statement, and Total Number of Issued and Outstanding Shares. Financial statements must
be prepared in accordance with US GAAP, but are not required to be audited. (Please note that Cash Flow Statements are not required to qualify for the Limited Information tier; however, unless the financial statements include a Cash Flow Statement, no financial data will be included in the OTC Financials Data Service, which
distributes company financial data to online investor portals and makes the data available on your company’s Financials tab on www.otcmarkets.com)
? A company in the Limited Information tier, may, but is not required to, include information in accordance with these
OTC Pink Basic Disclosure Guidelines using the fillable form beginning on page 3.

My Translation:

A company that has an Annual Report or Quarterly Report filed in the last 6 months, but is 45 days late (but no more than 60 days late) on an Annual or Quarterly Report enters the Limited Information tier and gets a Yield Sign.

If the above company allows 60 days to pass without an updated Quarterly or annual report (based on what time of year it is), a Stop Sign is posted on OTCmarkets which corresponds to the No Information tier.

To remove the stop sign a company has to become current. If using the Alternative Reporting Standard (ARS) they will have to provide the required filings (Quarterly and Annual Reports) with financial statements following the GAAP Standards. A pink company can choose to be SEC compliant and disclose information and filings to the SEC's EDGAR system.

Since TRKG has a stop sign they were at one point in their history "Current" so they had done the "Initial Qualification" including the 2 years of required financial statements. However, it has been a long time since they were current, so they may have to do the Initial Qualification again, requiring financial statements from the previous 2 years. Otherwise they will just need to file an updated Quarterly Report to remove the stop sign.