I can't say for sure but I would definitely lean towards this:
Yes.. the company would never wish to put itself in trade-for-trade. It is solely done at the discretion of stock exchange and regulatory authorities.
In all of the cases of OTC companies that are put into this position, how many of them were actually manipulated by outside sources illegally versus how many of them turned out to be the companies financing scheme?
I haven't researched that, but, my guess is that it's leaning towards it's always the company. Just the way I am with the OTC land. Don't believe it till you read it in a proper filing.
It is solely done at the discretion of stock exchange and regulatory authorities.