As per OTC Markets Compliance, AFFU after garnering OTCID status would only be downgraded to the EM if AFFU had more than 16 months between Annual Reports. OTC Markets has a their own requirement of no longer than 12 months w/o the Verified Profile yet that would not be a further downgrade they just would not be eligible to regain OTCID. AFFU also would not need a new Management Certification as that is only required for Annuals (once a year). They would need if the company, AFFU deems it a Material Even simply needs a Supplemental Filing posted under the Disclosure Section
Pink Limited Information comes after Company misses filing deadlines (after the 5-day NT grace & downgraded on day 6 as you stated OTC downgrades them to Pink Limited. So filing the Q2 today would actually only mean getting restored to OTCID sooner.
A company can stay Pink Limited indefinitely, so long as: Their most recent Annual Report is not older than 16 months & Their Verified Company Profile on OTCIQ is updated within the past 12 months.
Expert Market Trigger(s) Company moves to Expert Market only if it's been More than 16 months have elapsed since the last Annual Report In the above scenario, OTC moves any company to the EM & restricts retail quotes entirely as OTC Markets has to follow SEC Rule 15c2-11
As it relates to the Verified Company Profile that needs to be updated every 12 months This is OTC Markets rule only & is a requirement to either maintain or get back on OTCID tier.
For Pink Current Restoration If any delinquent filing is submitted late but still within the 16-month/12-month windows, the company pops right back up to Pink Current (OTCID) once posted.
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