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Thursday, February 11, 2021 5:33:39 PM
mm's do not sponsor companies that may be facing further enforcement action
What I'm disputing is precisely your certainty in the contention that the company may be facing further enforcement action. We don't even know for certain why they were suspended. From Investopedia...
Suspended Trading
Securities trading on national exchanges, such as the NYSE or NASDAQ, can immediately resume trading when a suspension is lifted. When it comes to over-the-counter securities, broker-dealers cannot solicit investors to buy or sell previously-suspended securities until certain requirements are met, but unsolicited trading is permitted.
In particular, broker-dealers must fill out Form 211 with FINRA representing that they have satisfied all applicable requirements of Rule 15c2-11 and FINRA Rule 6432. These rules make sure that broker-dealers have reason to believe that its financial statements and other documents are accurate.
Often times, the price of securities move sharply lower following a suspension since there may be a lack of confidence in management. The price may quickly recover, however, if the issues are deemed to have been resolved.
Moreover, COUV seems to have backing from a very reputable law firm and investors who may hold some personal connections and sway with one or more MM's. As for your contention about further enforcement action, the MM has no exposure on that score, only on the accuracy of their form 211 submission, since FINRA would not approve the 211 if they anticipated further investigation...
Investor Bulletin: Trading Suspensions
No broker-dealer may solicit or recommend that an investor buy an OTC stock that has been subject to a trading suspension unless and until FINRA has approved a Form 211 relating to the stock. If there are continuing regulatory concerns about the company, its disclosures, or other factors, such as a pending regulatory investigation, a Form 211 application may not be approved...
...For stocks that are quoted in the OTC market (e.g. stocks quoted on DBOT ATS, Global OTC ATS, and OTC Link ATS, among other venues), quoting does not automatically resume when a ten-day suspension ends. Before OTC stock quoting can resume after a suspension period, SEC regulations require a broker-dealer to review specific information about the company in accordance with Exchange Act Rule 15c2-11 and FINRA Rule 6432. If a broker-dealer does not have confidence that a company's financial statements are reasonably current and accurate in all material respects, especially in light of the questions that may have been raised by the SEC suspension action, then a broker-dealer may not publish a quote for the company's stock. The OTC markets function through dealer systems where only broker-dealers may quote and facilitate trading in OTC stocks.
Les
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