If the accounting dept is reasonably up to date th

If the accounting dept is reasonably up to date they could upgrade in a month - even less- because they already have most of the information- just depends on what accounting staff they have.

the only new info they would need would be an, "Attorney Letter with Respect to Ccurrent Info ", certifying that info provided complies w the definition of ''current info'' in rule 15c2-11(a)(5) of the Securities Act of 1934 and rule 144(c)(2) of Securities Act of 1933.
Unlike rule 144 letters, agencies are typically pretty lenient re such letters-many such letters are actually done by unqualified attorneys in fly by night shops who pump them out like a grist mill- but suppose to be done by a qualified securities attorney

Other info which they already have would typically be things like:

1) ''Articles of incorporation and bylaws''

2) ''Initial Company info and disclosure statement''

(e.g. history of how the company came into existence. Typically a company is formed and it is bought out or JV'd by or with another company etc- its very common for their to be several such reiterations, so they want investors to be able to see that).

3) Unaudited ''Quarterly Accounting Report''

- I've literally read thousands of such penny company reports as part of my dd in choosing a company-only takes a minute per company. These unaudited statements could merely be a presentation of management w no outside review- thats pretty common in the current info class or they could be a limited review report reviewed by an outside accountant -but that entails very little work compared to an audit
most of the current info quarterly reports I've seen are actually a joke from an accounting viewpoint (I have,inter alia, a full accounting degree summa cum laude) and very easy for the accounting dept to produce.

penny co classifications and qualifications have changed so rapidly over the years, as i've previously briefly detailed, brokers are so ignorant re current penny co rules that many think its still the pre-1999 wild west and dont know present penny co disclosure requirements.
I spoke w 1 such broker for quite some time and to rebut his ignorance I mentioned OTCQX 7 times which has accounting etc disclosures similar to the big exchanges -just w less fees etc-so many foreign blue chips are on OTCQX. He still did not understand and after a pause -in which he looked up OTCQX- he had never heard of it before!! came back and said thats a mutual fund company-a monkey would be smarter.

for a real life example go to otcmarkets.com and under filings and disclosures look at page 5 of PIHN