You are missing the fact that it does not need to be effective immediately, to force the OTC Markets to remove the dark/defunct and 15 day timer.
It is audited. It is 2 years of annual audits, A-Z registration, covering everything, including tons of stuff the OTC does not even require.
The OTC does not have the authority to put on EM market, once the Form 10 is filed. In fact they must remove the dark defunct and timer, because it is no longer "dark"..
Bullish