My concern is having plenty of headroom. Given the volatility in OTC stocks, the company will want to trade well above the $4 range, at least above $6. Don’t want on day 89 some volatility that drops the close pricing below $4, and then have to start the clock all over again.
The company could certainly wait until after TLD to determine that whatever price the stock settles at is sufficient on its own not to need a R/S.