Yet a Form 211 doesnt get removed over a CE tier change and there are companies with CE that have a Form 211. So that logic is flawed, in this specific case it was an SEC SUSPENSION that resulted in a CE being placed onto the security by OTC Markets immediately, the loss of the Form 211 did not occur until after 10 trading days. So ten days after the CE was issued then the Form 211 was pulled, so they are SEPARATE actions. The OTC Markets explains this clearly that they are exclusive of each other:
Quote:When Does Caveat Emptor Get Removed?
OTC Markets Group may review a Caveat Emptor designation upon request by the company and may determine, in its sole discretion, to remove the designation. The Caveat Emptor designation is typically not removed within the first 30 days of designation. To be eligible for a review, a company must meet the qualifications for Pink Current Information, have a verified the information on its company profile on www.otcmarkets.com, and demonstrate to OTC Markets Group that there is no longer a public interest concern. OTC Markets Group requires Caveat Emptor securities that are not eligible for proprietary broker quotations (Unsolicited Only) to have a Form 211 cleared by FINRA in order to be eligible for a review (e.g. securities previously halted or trade suspended by a regulatory authority).
There is a reason for this, as OTC markets can on their own issue a CE at anytime without a regulatory action. A promotion on a stock is often the cause and a CE is applied, but it has no effect on the Form 211 or quotation. Now there are brokerages that may refuse to allow the purchase of CE Securities, but nothing to do with a Form 211 in that case, just a specific policy for that brokerage.
For this security the CE is in place because of the suspension as it is clearly defined as a reason for a CE to be applied, not the loss of a Form 211. The Suspension is the cause of the loss of the Form 211.
There are securities with no Form 211 and are not CE, they are unsolicited quote securities and those all ended up on the "Expert Market" recently.
A recap, a CE can be applied at anytime OTC markets deems so, even if there is an active Form 211 present as it has nothing to do with their CE designation policy. You can get a new Form 211 approved and yet OTC Markets can still apply the CE as per their own disclosure.