The big dogs at OTC Markets have the power to decide things like that now at their "sole discretion". So, if they want a company to do it then yes. It's that or they get slapped with a shell risk and it severely restricts firms from buying the stock. Take for example Heineken beer. The company trades on the OTC Markets for 50 bucks a share. If OTC Markets "wanted to" they have the sole and absolute power to label that company a "shell risk" without any explanation. Hate to think they would want MR. Dylan Mulvaney on the bottle. But stranger things have happened. Not that I fear they would actually do that but it's the point of the matter. They have the authority to rain hell on a stock price by labeling it shell risk.That alone could lead to corruption and manipulation.
Also, OTC Markets is publicly traded themselves. Who get's to slap them with a "shell risk" flag if they desire? No watch dog watching the watch dog. I read the procedure and Ben can write OTC Markets a letter begging them to have mercy on his company. Public filing last February was not the ticket to getting in their good graces. Hell, maybe they want a Christmas Card also? They never disclosed the metrics.