The SEC and FINRA have regulatory powers as a government entity and SRO respectively. OTCM does not have any such powers and is a for profit company. The SEC is much more likely to have been in possession of the information first and may have passed along to OTCM than the other way around. The only difference is that OTCM would be able to take action quicker (apply the CE) than the SEC would simply because the SEC has a process to work through to approve such a suspension, so it would appear that OTCM action led the way.
However, it is highly unlikely that the CE is what prompted the SEC to "look" at or take action on EPTI, they were already well down a path of being interested.
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