OTC Pinks do not need to file to the SEC but they are still required and expected to file unaudited yearly Financials and accurate corporate data to the SEC and Finra approved OTC Markets, aka Pink Sheets.
Even after an SEC Suspension and simultaneous ADMIN Proceeding a company that is delinquent in filing unaudited Financials to the OTC Markets still has a chance to redeem themselves by Filing to the OTC. Still, such a delinquent company will likely remain on the Grey Sheets unless the delinquent company audits at least 2 full years of Financials, but the delinquent company can at least avoid revocation which WILL happen if they don't submit all required unaudited Financials.
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