I have actually talked to the SEC, FINRA, DTCC, and some Market Makers on this matter, all in separate conversations of course. The best way is to become current with a new Form 10 and remedy any comments by the SEC, FINRA, DTCC. Every issuer is different. If they have not filed in 5 years, they have to catch up on all 5 years of filings. Or they can 15-12b and file a new Form 10 or S1 with 3 years Balance, and two years of each cash flow and p&l. If I company is never a filer, file an initial Form 10 or S1 and get compliant. MMs do not want to file a scam Form 211 anymore unless they stand to make gazillions of dollars and are willing to pay the fine if they get caught, which is most likely around $50,000. Its all business.
Don't forget, you can get a 211 through FINRA , but can you get DTCC to clear you for electronic transfer? If they "Global Lock" the issuer, its still a worthless shell because they cannot print, deposit and dump. Also known as "pump and dump".