VirTra Inc (VTSI)

[Portguyofva]

I'm definitely not an expert in OTCQX reporting requirements, but from what I do know, I don't agree with the statement "As far as up listing with OTCQX, the company must be SEC Reporting company to submit that application."

One of the key positive aspects for a Micro/Nano-cap company on the OTCQX is the opportunity to conduct "Alternative Reporting" versus SEC Reporting. From the OTC Markets website at http://www.otcmarkets.com/learn/otc-company-reporting "OTCQX U.S companies not reporting to the SEC can follow the Alternative Reporting Standard. These companies submit information pursuant to the OTCQX U.S. Disclosure Guidelines and are subject to the eligibility requirements and terms of the OTCQX Rules for U.S. Companies. OTCQX companies provide current and potential investors with a set of "material" information to help investors make a sound investment decision. OTCQX company disclosure enables an investor to understand the company’s business operations and prospects.

The detailed Alternative Reporting requirements can be viewed here: http://www.otcmarkets.com/content/doc/OTCQXGuidelines.pdf

SEC reporting requirements can be viewed here: http://www.sec.gov/investor/pubs/microcapstock.htm

Virtra is a "Nanocap" company with less than $10M in assets and less than 2000 share-holders of record and is not required to submit reports to the SEC and has not been reporting to the SEC since 2008, which IMO makes Virtra eligible to report via OTC Markets Alternative Reporting.

I would recommend a re-engagement with Rudy and/or Bob on the comment "As far as up listing with OTCQX, the company must be SEC Reporting company to submit that application."

Also of interest on this topic is the requirement for a DAD (Designated Advisor for Disclosure) by the OTC Markets if using Alternative Reporting. DAD fees can range from $15K to $100K per year for a company. See below comment from the following link:
http://www.valueinvestorsclub.com/idea/OTC_MARKETS_GROUP_INC/63425

"Also, OTCM has a free, hard working, and growing sales force in the form of the investment banks and law firms that are encouraging qualified companies to hire them to be the DAD/PAL required to list on the OTCQX and stay listed. The DAD/PAL could charge anything from about $15,000 a year for fairly bare-bones service that covers the basic paperwork to well over $100,000 per year for very full service that includes regular updates on market activity, road show trips to meet potential US investors, lining up research coverage, consulting on acquisition possibilities in the US market, and any number of other services. Investment bankers and lawyers, like anyone else, want clients who provide recurring revenues and an opportunity to earn larger fees on specific projects."

I'm not sure if Miller Group is a registered DAD or not with the OTC Markets, but they should be. The cost is minimal at one-time $1k filing fee and annual fee of $1k. From my research, the cost for Virtra to uplist to the OTCQX is around $5k application fee; $10K or $15K annual fee to OTC Markets; and $15K to $100K annual fee for a DAD. This is no where near the annual costs Virtra alluded to in their 2008 letter posted by Ardly at post #36955. Inquisitive minds want to know?? GLTA!