This looks remarkably similar to BVTK. The conversions are likely occurring under Section 4(a)1 exemption from registration.
There is no rule or predictability to an SEC suspension for delinquency...but in cases like this where there is very active trading suddenly occurring one would hope they take notice.
Re ECOS: The company stopped filing after their 10Q for Sept. 2014. In March and April 2017 the company filed the 2014 10K, 3 quarterly 10Q's and year end 10K for 2015. The company is still severely delinquent for all of 2016 and 2017 to date. ****On Feb 17,2015 ECOS did a one for 2,000 reverse split.
I didn't have time to check for any convertible debentures but I'm reasonably certain there are CD's that the company and lender wanted to convert as observed by approximately 12 billion shares traded since they updated their 2015 Financials in March/April 2017, and of that 12 billion traded shares 6.3 billion have traded since July 5,2017.
The SEC needs to be alerted to the suspicious timing of 12 billion trading volumes in the last 3 1/2 months, immediately after filing their delinquent 2014/2015 Financials. Gatekeepers are supposed to submit Suspicious Activity Reports (SARs) to the SEC. Unfortunately the public is not informed if/when any Gatekeeper submits SARs to the SEC. However, the public can submit their own documented evidence of suspicious activities to the SEC....crossed fingers that they ever take action. They must use a dart board to determine which stocks receive Enforcement Actions (ie., Suspension, Admin Proceeding, Revocation) because there is no known timeframe template for taking Enforcement Action(s).
As far as I know there is no formal SEC policy for any registered company being "partially compliant". A company is either compliant to their filing obligations or they are non-compliant, and ECOS is delinquent all of 2016 and 2017 to date.
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