The 211 form may look simple to you, but the underlying factual paperwork to "vouch" for is huge and filled with extreme consequences for whoever signs off, which they won't do with a company under investigation.
could a grey market listed company approach a MM about filing a 211 for them.. the form is very simple 2 page process which could be filled out in a matter of minutes...
Yes, they could approach an MM. But the form isn't "simple" at all. This is what's required: