There may have been provisions for additional restrictions, but the big question is whether or not it has been reviewed and upheld in court at this point. Until he's slapped with a court order freezing his RMHB investments then it would be reasonable to expect that he'd hurry and unload as much as he could in advance of any such action (up to 1.5% per quarter). If they needed more funds to move ahead with some key step(s) like getting the water to market or setting up another production run, it could at least partially be the guys selling whatever number of shares are required to raise the necessary amount. A short term lag is all we're seeing here, caused by the delay to the uplist and the fact that day traders were most likely primarily responsible for the pre-uplist spike in the pps. They were surely anticipating a nice pop not long after the fully reporting status and the uplist were official.