The information you posted is for non-reporting pink sheet companies - NPHC doesn't qualify for the exception.
A OTC shell company would be able to qualify as compliant with Rule 15c2-11 only if it was new to the market. The shell company would have 18 months to find a buyer.
The amendments to Rule 15c2-11 are to remove non-reporting pinkys that aren't current. NPHC has to be current and there isn't any exemptions.
"The new 15(c)211 rules basically states that a broker cannot quote a security unless they are "current" in their reporting obligations. The tricky part is that the SEC defines "current" as '.. having financial data available within 12 months and three days of a quotation."