TRCPA - There are some interesting nuances in all of the regs. One important distinction seems to be the number of shareholders. A larger percentage of them don't hold very many shares - 100's or less. Just the same, it is a distinction with a big impact apparently.
While they work through the issues regarding where the shares are traded, the one thing that has been lost in the discussion is what are they doing with sales? If those don't finalize, it really won't matter since there clearly won't be enough cash to pay for the audits. With that said, I believe they have a couple of large sales that are in the works. That would be important to find out more about.