That is correct. OTCBBs cannot request a halt for the simple reason that the NASD has no authority to halt, unless the stock is a derivative of a stock traded on a national exchange (or foreign). Only SEC can suspend trading in a domestic OTCBB
"You can't be a real country unless you have a beer and an airline - it helps if you have some kind of a football team, or some nuclear weapons, but at the very least you need a beer". F Zappa
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