I stick to my former interpretation.

Read:

"(e) Notwithstanding the foregoing paragraphs, a member shall not be permitted to quote a security if:"

IMO, what this is saying is that, satisfying any "if", the member will be delisted (not permitted to quote).

"(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..."

I read this as an extension = late. It says "including", not "excluding".

Think it through.... No company would file late without having (to) first filed for an extension. Further, if this were not the correct interpretation, why would they need to include the parenthetical?

Now, if it said: ".....file a complete required annual or quarterly report by the due date or extended due date for such report.....", I'd buy your interpretation. But it doesn't.

Key words: "due date"

JMHO, FWIW

SGE