I find that hard to believe, too. Clearly OTCMarkets has a way of tracking when companies become delinquent with their SEC filings, because they label them "SEC filer - Delinquent". You'd think the SEC would have that capability as well.
They could check for new delinquent filers once a month, and send letters. But as far as I can tell, they don't do it that way. Their approach seems to be much more random, as Renee said.
The only time we ever see references to delinquency letters is in suspension notices and OIPs. They say something like: "A delinquency letter was sent to the Company's last known address on [fill in date here], and no reply was received". Nowadays, most of the letters seem to have been sent between two and one-and-a-half years earlier. But sometimes it's four or five years earlier.
There really isn't any excuse...
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