what "additional documentation and approval"? to get on the OTCBB you need to be an SEC reporting company and have a sponsoring market maker. the sponsoring market maker, if for some reason new 211 information is required, uses the SEC filing as the basis for that new information. the key doc is still the SEC Form 10 filing, which can't be used until 60 days after it's initial filing and can't be used for OTCBB purposes until all SEC comments have been cleared (which is often beyond 60 days).
and the SEC staff is known to take a long look at companies that want to come back to SEC-life after voluntarily going dark -- including questions about the company's eligibility to have filed a Form 15 to go dark in the first place.
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