Put it this way, if it were on Pinks, there would be a bid/ask. Well, maybe not with unsolicited Pinks. At any rate, a Form 211 would've been filed...There simply hasn't been enough time to have that form approved.
As far as I know, nothing legally stops the company from going ahead with filing its cash divvy with NASDAQ. Of course, doing so now makes even less business sense than it did before.