There has been no change of late in any “paper trail” requirements for consultants. If the consultant is not keeping track and getting the required documentation that is on them.
But there is no default to 2 years if the consultant can reasonably establish when the work was completed. I think what you are referring to may be the 4(a)1 exemption that allows restricted stock to become free trading with no “paperwork” after about 2 years. This exemption is used in cases where a holder of stock in a company that has gone dark and stopped filing needs some mechanism to get the restriction removed.
The other issue in the OTC separate from that is that “clearing” of penny certs is becoming much more difficult overall...especially below $0.01. But that is across the board for ANY penny stock issuance...that may be what you are seeing.
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