Thursday, April 16, 2020 3:04:47 PM
it seems ARYC needs to file docs form 211 with broker-dealer and they must comply w FINRA 6432 and SEC rule 15c2-11.
SEC rule 15c2-11 calls for meeting past SEC filing requirements.
however:
if OTC security quoted in last 30 days calendar days, and during those 30 days the OTC security was quoted on at least 12 days without more than 4 consecutive business days without quotations, then a subsequent broker-dealer may "piggyback" off of this previous quotation and does not need to meet the requirements of rule 15c2-11.
because of this exception, it's unclear if ARYC would need to file all past SEC required documents, when submitting form 211 to a broker-dealer.
anyone have experience with this?
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