OTC Markets expects both documents to be filed at the same time in order to maintain the Current tier. That being said, they allow a 30 day grace period for the attorney letter to be filed in order to still be considered a timely filing. The tier upgrade/downgrade is an automated process; if the system only sees one of two documents filed on the annual filing due date, it will downgrade the tier. Once the second document is filed, it will upgrade the tier.
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