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Monday, May 04, 2020 12:36:55 PM
they don't want to take the responsibility for a company
Nothing in the 211 requires the submitter to 'take responsibility for' the company for which they are submitting the request. The company reaches out to them and asks that they submit the form:
"An exchange delisted issuer that wishes to be quoted on the OTCBB should contact their market makers to request that they complete a Form 211 for review and processing."
https://www.finra.org/filing-reporting/market-transparency-reporting/otcbb/faq#600
Supplemental information (from 211)
a - Describe the circumstances surrounding the submission of this application. Include the identity of any person(s) for whom the quotation is being submitted and any information provided to your firm by such person(s).
b - Has the Issuer or its predecessor (if any) been subject to a trading suspension order issued by the SEC during the past 12 months? If a trading suspension order has been issued, provide a copy of the order or of the SEC’s public release announcing the trading suspension order
c - Has the Issuer or its predecessor (if any) been subject to a trading suspension order issued by the SEC during the past 12 months? If a trading suspension order has been issued, provide a copy of the order or of the SEC’s public release announcing the trading suspension order
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