Technically, you are very, very correct. As a Pinkie on Limited Information they are in compliance with their low category on OTC. However, that very lack of transparency and lackadaisical attitude toward filing is going to be one element that scares off the investors he needs. If he has aspirations of moving to QB, it would do Howard well to ACT like an SEC reporting company. Don't dress for the job you have; dress for the job you want.