I can’t comment much on the information provided, as I only just started following.
What I can say for fact, is that the DTC does not place a chill on a stock for delinquent financials.
Pinks have no reporting requirements.
The DTC places chills when the have questions about the validity of stock issued in transactions and which exemptions they were issued under.
That’s it. Period.
Usually after 12-18 months of being chilled, along with no share issuances, the company can request the chill be lifted.
The request to the DTC is farmed out to a couple of retained law firms for review and recommendation.
The DTC follows the recommendation of the outside law firm.
If the company hasn’t issued any shares that have entered the public market, lifting the chill would be a no brainer