Bahnsen posted a Notice of Late Filing but hasn't given any explanation as to why the attorney opinion letter has been removed from www.otcmarkets.com. She stated the overdue disclosures will be filed by 9/30/21, which is after the SEC's deadline requiring disclosures to be current.
Doesn't she have to obtain an attorney opinion letter before the September 26, 2021 effective date for Rule 15c2-11? Can she obtain an opinion letter before late disclosures are filed?