Here's the rule.
"(e) Notwithstanding the foregoing paragraphs, a member shall not be permitted to quote a security if:
(1) while quoted on the OTCBB, the issuer of the security has failed to file a complete required annual or quarterly report by the due date for such report (including, if applicable, any extensions permitted by SEC Rule 12b-25) three times in the prior two-year period; or
(2) the security has been removed from the OTCBB due to the issuer's failure to satisfy paragraph (a)(2), (3) or (4), above, two times in the prior two-year period."
I read it differently than your and SGE's interpretation. To me, it indicates that extensions are not counted on the "3 strike" tally. Extensions are permitted, but not filing on time (getting the "E") is the big no-no.
Maybe Fut can clarify??