Yes, that convertible debt is an interesting feature. And oddly, he always seems to award himself approximately the same amount. In some cases--BILB is one--if it were all converted at once, the result would be a control block. In others, it would result in a more modest slice of the public float.
Technically, of course, these are custodianship shells, and Rule 144 wouldn't be available to holders of restricted stock for one year after the "new" company declared itself to be operational, no matter how "aged" the debt was.
But Tracy has his own transfer agency, Cathedral Stock Transfer. Oddly, though he formed it in Louisiana in 2012, it doesn't appear to have any clients. If it does, they aren't listed on the OTCMarkets Service Providers list. It isn't difficult to see how handy it would be to have one's own transfer agency in situations like the ones described above…
I wouldn't be surprised if he were to write opinions freeing up stock. Unfortunately, if he does, we won't be able to see them.