The SEC has been suspending delinquent filers both SEC registered and not. There is a whole task team at the SEC now that is cleaning up the issuers that are not filing, appear to be dormant, or they cannot reach or suspect a ticker could be subject to highjacking. The SEC has the authority suspend any stock it chooses for questionable filings or the lack thereof. While they often go after delinquent filers more often, they have been getting some OTC only filers as well.
I concur with your opening remarks and we are not heading to the grey sheets but as far as an SEC investigation....I can't see them taking 2+ years to investigate a relatively simple business model. I don't think that is the issue here. The issue is a grossly immature and incompetent CEO.