STHC is definitely a "shell" imho. This is despite the fact that STHC declared itself NOT a shell back in 2015 when they filed their last 10-K to the SEC.
I don't think anyone could reasonably argue that STHC is not a shell currently. The fact is that most companies with stop signs on the OTC are in fact non-operating shells.
The things that distinguish the shell company STHC from other shells, is that STHC was given a custodian by the Delaware courts, and the custodian then transferred ownership of the company to another individual (Mark Bolster).
Unfortunately, none of these events have been officially documented via an OTC disclosure or via an SEC document. So in my view, STHC is in sort of an "undefined" state of transition from a shell to a legitimate operating company.
So to your question, what will happen when the OTC Markets deadline passes and the SEC deadline has been reached and a company like STHC, which could be considered a shell but one which is in the process of becoming a non-shell entity? My opinion is that OTC Markets will have to come up with some sort of system that distinguishes between shell companies that are not in the process of becoming a non-shell entity and those that are in the process of becoming a non-shell company (like STHC). I cannot predict how OTC Markets will handle this situation.
However, my guess would be that OTC Markets will remove the stop sign for "inactive" shells and put them on the grey market as of Sept. 28. Other "active" shells might be able to keep their current designation as a PINK company, but with a stop sign.
Guessing again, I would say that any shell that is actively in the process of becoming a non-shell company should still be allowed to have quotations published for 180 days according to the SEC exemption that is described in the new Rule. Whether that is with a stop sign or some other warning symbol, I cannot say.
I'm sure that OTC Markets is working on this problem and either have already come up with a solution, but have not published it yet, or will come up with a solution before the SEC deadline of Sept. 28.
In conclusion, I would urge all OTC traders to not panic as these deadlines approach. Perhaps no further information will be released before the June 30 "deadline", but I believe that more information will be released before the Sept. 28 deadline.
Only holders of shares in non-current companies that either are not shells or are shells that are not actively in the process of becoming a non-shell company should be worried about not having quotes for those shares come Sept. 28. imho
