Again, if they file the letter and then the OTC requires them to submit amendeded documents, they then need the attorney to submit a second letter to file.
So if they wait till they are pink limited they need only submit a single letter.
Do you understand? So sure they can submit one now, they may then need to submit another one if the OTC does not accept their filings, so why file one until you know that the filings were accepted by the OTC?