The Form 3 (and Form 4) is not a FINRA regulated form, so I don't believe that the OTC market tier has any bearing on the requirement.
The 10% ownership must be in an "issuer with a class of equity securities registered pursuant to Section 12 of the Securities Exchange Act of 1934" and as you point out it is not an obligation of the issuer.
Given that the company's status viv-a-vis registered pursuant, etc. has not been changed I believe the individuals filings are still required. The 13 G issue is more complicated and I'm going to duck it.
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