If the SEC wants all pinks to be fully reporting so be it. In regards to those who have gone to "alternative reporting standards" and only have, at best, unaudited financials available, is the cost of filing really that prohibitive?
In regards to transfer agents, perhaps a step in the right direction would be to require them to keep and divulge up to date share structures of their clients. I've heard some say TAs grumble at the number of phone calls, but couldn't they keep a spreadsheet posted online that is updated daily?