There very well could be...but there's also potential thats not the case.
No, there isn't. Maybe Continental got brownie points from OTCMarkets for simply complying, or appearing to comply. As I recall--I'm too lazy to look it up--when OTCM most recently announced this plan, it contemplated punishments for companies unwilling to go along with it. I'm too lazy to look it up, but I believe that was for the issuers, not the transfer agents.
However, it's conceivable Continental just thought it'd be easier to offer whatever numbers it had, rather than try to contact these long-dead companies.