Uhhh no, the only pieces required are simply the 39 page document completed and a separate filing called the attorney opinion letter vouching for the accuracy of those filings.
They may amend to these at a later date since some of that is covered in the first couple of pages, but that summary report is absolutely not required. I suggest reading the OTC Guide and quit making assumptions and become educated in how this all works.
Non-reporting Companies with Current Information Available on otcmarkets.com
Non-SEC registered companies that meet the following requirements will be identified as providing Current Information:
1. Subscribe to the OTC Disclosure and News Service (see Subscription Agreement)
2. Publish disclosure that complies with Pink OTC Markets' Guidelines for Providing Adequate Current Information (PDF) through the OTC Disclosure and News Service.
3. Attorney Letter - The company must publish a quarterly letter from an attorney stating that the issuer's disclosure (i)constitutes "adequate current public information" concerning the Securities and the Issuer and "is available" within the meaning of Rule 144(c)(2) under the Securities Act, (ii) includes all of the information that a broker-dealer would be required to obtain from the Issuer to publish a quotation for the Securities under Rule 15c2-11 under the Securities Exchange Act of 1934 (the "Exchange Act"), and (iii) complies as to form with Pink OTC Markets' Guidelines for Providing Adequate Current Information. The letter must also identify the person responsible for the preparation of the financial statements.
For complete information requirements regarding the Attorney Letter, see Pink OTC Markets' Guidelines for Attorney Letters with Respect to Adequate Current Information (PDF).
4. Transfer Agent - The company must have an SEC registered transfer agent.
All right there in black and white, no magic about it....
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