From what you said, this appears to be the financial requirements: "For non-reporting company listings on the Pink Sheets, please provide audited or non-audited financial statements. Provide the last 2 fiscal years, if applicable, for the issuer or any predecessor."
So, at a minimum, they need to produce non-audited financials for 2009 and 2010. They do not have to go back farther than that. I actually think this will not be that difficult. The more onerous requirements come under the paragraphs dealing with:
" For any private placements (past year or since inception) provide the details of the private offering including who solicited investors, how they were known to the solicitor, and how many individuals were solicited whom did not purchase.
Provide one full copy of the subscription agreement. Also provide the signature pages of all subscription agreements subscribed by each investor and any other pages that have writing on them indicating the dollar amount and number of shares subscribed in the subscription agreement. Include copies of all checks by the subscribers. If there were more than one offering memorandum/circular used, provide the same information requested herein.
Include any additional Form D's filed with the SEC.
The following items are needed when available:
Date the offering closed:
Number of shares sold:
Final offering price:
The date the certificates will be or where delivered to shareholders:
Provide a spreadsheet showing all relationships among and between every shareholder and the issuer and its predecessor, its present and prior officers and directors, and other shareholders."
This may not be as easy to produce or certify its accuracy.
