Seeker, those are the rules, but...
1. Many people/attorneys have been caught/charged/convicted for making up reasons that the restricted shares should be unrestricted sooner than the 12 month period. I do believe it frequently occurs in penny market and many don't get caught. Gendarme is an example of one that got caught.
2. There is another way the company can issue free trading shares. It is called a debt wrap. If the company has a loan or obligation outstanding for more than one year, it is considered "aged debt". Generally, an investor seeking discounted free trading shares, in conjunction with the Company's management, will buy the debt at par. Then negotiate a conversion of the debt into discounted shares. As the debt has been outstanding for more than one year, the shares received as repayment are free trading.
Debt wraps have become more popular given the conversion into free trading shares. Discounts range from 25-50%.
The problem now for RCCH is that the SEC/DTC/Finra has cracked down on the market and brokerages. So the overwhelming majority of US and Canadian brokerages won't accept, for deposit, stock certs for penny stocks that are chilled, trade on the greys, or are on a trade for trade status.
Most players accepting shares for discounts, are now using accounts in the Cayman Islands or Germany. They are more willing to accept penny stock certs for deposit.
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