Filing to OTC can be done before AF's, IMO. I believe the 15C-211 could have been done long back, and then AF's when ready, can be filed. This would have cut down on the lead time.
I have no idea why EI has a different plan to file for OTC, if that is their goal. Clint indicated that they plan to file the Form SB-2. It takes 30-90 days, same as a 15C-211. It is possible that Costs may be a factor here, as Sb-2 is a cheaper route. It will be a longer wait for us, IMO.