Correction: My post incorrectly included the following quote from my source...
Among other changes to the securities laws, the NDAA amends the Securities Exchange Act of 1934 to codify the SEC’s authority to seek disgorgement from persons who receive unjust enrichment. It also extends to ten years the statute of limitations applicable to disgorgement claims arising from violations of the anti-fraud provisions of the securities laws, including Section 10(b) of the Exchange Act and Section 17(a)(1) of the Securities Act of 1933. But while the new legislation formalizes certain aspects of the SEC’s disgorgement authority, it freezes, and in some cases scales back, the SEC’s ability to seek other remedies...
...it was actually a quote from the source that was quoted in the post I was replying to. Here's the actual source for that quote which I included to show that the original quote was confined to "disgorgement actions"...
Yeah, well, the company says they'll need a 211, so we'll go with that. I expect it's because even OTC Markets would hesitate to pop a company back into trading after being cited for false information in the public marketplace (aka - fraud) by the SEC. Delinquent financials is one thing that can be healed, regaining trust after fraud is a bit more difficult.