There is no back fee in this case you begin with a new account in this case since they didn't bother to maintain the account. You owe $1000 for the application and either $5k annually or $3k bi annually for he ability to upload documents.
The transfer agent certainly can be a delay. Why would anyone try to get an OTC account that isn't current on the TA?
There is only one form which I linked. That is the entire submission.
So it isn't difficult but if a company can't pay its bills yes it won't happen. Not sure why anyone would try.
However believe whatever you want but I will still put our accurate information.