I have a different perspective, have you ever worked for the gov't, I have both federal and local.
All those regs/laws are important and to be enforced, but when the gov't "knows" that things are legit and files are completed, gov't allows some leeway for credible reasons.
And a credible reason for delayed filings would be to align themselves up to the point where they will be uplisted, then filings occur. Why, because they don't want to release the filings too early so mkt price goes up uncontrollably, perhaps, causing a halt in trading. Both SEC and OTC and FINRA want a legit company to come to mkt in a stable environment.
Enforcement is not necessarily by the letter of the law, but the spirit.