Okay, I have an answer. While I don't find it entirely satisfactory, It explains what's happening.
I called Issuer Services at OTCM. The first person I spoke with didn't have an answer, but the second, who evidently is involved directly with OTC Link, understood what I was asking.
So this is the explanation: the stocks in question do not have new Forms 211. They're trading unsolicited. That is, an MM called OTCM and said he had requests from people who wanted to trade the stock, and so OTCM agreed to let them do it.
In the recent past, when stocks like these traded unsolicited, there was a big warning in red on the "Overview" page at OTC Markets, noting: THIS STOCK IS TRADING ON AN UNSOLICITED BASIS. For some reason, they junked that warning and replaced it with one that is on its face incomprehensible:
Warning! This company may not be making material information publicly available
Buying or selling this security on the basis of material nonpublic material information is prohibited under Section 10(b) of the Securities Exchange Act of 1934 and Rules 10b-5 and 10b5-1 thereunder. Violators may be subject to civil and criminal penalties.
Once upon a time, OTCM took that view that trading on an unsolicited basis was undesirable, and strictly limited it. But it seems those days are over.
Check out XMET: So far, it's traded nearly a billion shares, and is up 14900 percent.
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