I encourage you do some more research on this subject - FINRA merely makes sure that all is in place for the filing process, which then dictates the timeline for when the split will go into effect.
I would venture to say there's an issue regarding the number of preferred shares in relation to the common, and how this potentially impacts common shareholders. Could there also be a question regarding the debt holders, possibly, but their percentage will be calculated in relation to the split going forward.
From the FINRA Website:
What is FINRA's role?
FINRA does not approve reverse splits, but it does process reverse stock splits as part of its functions related to company corporate actions in the OTC market. OTC companies must submit notice to FINRA 10 days prior to the record/effective date of the corporate action. Once a corporate action submission is successfully processed (which may take longer than 10 days), it will be posted to the OTC Daily List.