I just talked via e-mail with Anne, our adoption coordinator. She says that our file was actually submitted to PGN at the end of December! Because we have not received pre-approval from the U.S. embassy, this means that will will get an automatic previo and KO (kickout) from PGN for no pre-approval. The good thing about doing it this way is (1) our file was submitted to PGN before the Dec. 31 law change and has a much better chance of being "grandfathered in" and (2) there may be other previos in our file that PGN will notify our attorney about and these can be fixed before the file is re-submitted after our KO. These previos can be either on the Guatemalan side or on our side. So, now we wait for the actual KO (Anne says she expects it in the next few weeks), wait for the pre-approval from the embassy, fix any previos, and re-submit our file to PGN. After the re-submittal our file might receive another KO for other previos (lets pray that doesn't happen!!!!) or will be approved by PGN after 8 weeks.
Unfortunately, now PGN is saying that even files that were initially submitted before Dec. 31 will have to register with the new Central Authority (that is not quite up and running) before being re-submitted. Hopefully, this will simply be that our attorney needs to submit some paperwork at the office of the Central Authority, but the specifics haven't been released yet. The people on the Central Authority are just now being appointed by the new government. There was an announcement last week about the actual physical address in Guatemala of the Central Authority, so that's a step in the right direction!
If this whole process is TOTALLY confusing to you, check out one of my earliest posts where I try to explain the Guatemalan adoption process.