And there are some comments already, but as I said, nearly all address the same issue, which is OTC companies that are "successful"--at least by the commenters' estimation--but dark. There are, however, provisions in the new rule that would permit many of those companies to comply with the "current information" requirement.
I'm sure we'll be seeing more comments soon, perhaps from issuers, broker-dealers, and, I should think, FINRA, SIFMA, OTC Markets, and some state securities regulators.
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