MIngy - have just a few moments but saw your post want to answer best i can.
Forget there are two Acts, 1933 and 1934 - for practical purposes the later Act was passed to fill in holes on the 1933 act and add more regualtion
As for the E, it was dropped merely because we passed a certain period without filing and dropped off OTC - however we still have filings requirement because we were on the OTC - if we fail to file at some time in the future we could face a hearing about our registration - imo
We are late is why were are on the grays and can stay there for an unknown time period (yes could be 3 years - but hope not)
As far as any further regualtory action, so long as there is nothing improper with company operations, if we do not file a 10K the only thing spng faces is a hearing regarding revocation of its registration to be a public trading company - this can come anytime between now and the second coming - all depends when SEC wants to seek enforcement action - thats when there would be the notice, hearing and an ORder allowing revocation of registration.
I think you are correct, if SPNG becomes current in its filings then we get our quote back as a matter of law so long as all else is in order with the company - hope this helps and that i did not miss anything important