Could be - my thought is that the Certification Form does not have to be publicly posted, only filed using the OTC News and Disclosure service.
5.4 Responsibility for Content. The Company shall have complete responsibility, and the Company understands and agrees that OTC Markets Group will have no responsibility or liability whatsoever, for any and all Content, whetherpublicly postedorprivately delivered, transmitted, uploaded, posted, emailed or otherwise posted through OTCIQ by or on behalf of the Company using Company Credentials or otherwise...
Based on the language above, the application, OTCQB certification form and/or all other required material filings could currently be in OTC posession, under review/process and pending final action. Hopefully this is the case. It's my belief that it is. Time will tell.