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Re: rbtree post# 17829

Sunday, 03/07/2021 9:36:09 AM

Sunday, March 07, 2021 9:36:09 AM

Post# of 19369

IMO, they won't find an MM to file a Form 211 in that time frame.



The new rules allow OTC markets to reinstate them without a Form 211 or a FINRA review or an MM. All they really need is to bring their financial information current...

The SEC Has Adopted Final Amendments To Rule 15C2-11; Major Change For OTC Markets Companies

will add new exceptions for lower risk securities; and add the ability of OTC Markets itself to confirm that the requirements of Rule 15c2-11 or an exception have been met, and allow for broker-dealer to rely on that confirmation. Importantly the new rule will not require OTC Markets to submit a Form 211 application or otherwise have FINRA review its determination that a broker-dealer can quote a security, prior to the quotation by a broker-dealer...

OTC Markets can make a determination that a company qualifies for an exception to the 211 rule requirements and a broker-dealer can rely on that determination.

A broker-dealer can rely on the OTC Markets determination of the availability of the rule or an exception to quote a security without conducting an independent review. Keeping the rule’s current 3 business day requirement, a broker-dealer’s quotation must be published or submitted within three business days after the qualified IDQS (OTC Markets) makes a publicly available determination.

Importantly, the new rule specifically does not require that OTC Markets comply with FINRA Rule 6432 and does not require OTC Markets or broker-dealers relying on OTC Markets’ publicly available determination that an exception applies, to file Forms 211 with FINRA. I believe that the system will evolve such that OTC Markets completes the vast majority of 211 compliance reviews...


Les