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Re: garrox post# 111608

Monday, 03/01/2021 3:54:38 PM

Monday, March 01, 2021 3:54:38 PM

Post# of 111729
This is an Unsolicited quote security it has not Form 211, that is why it is "UNSOLICITED".



Unsolicited quotations on securities that fail to satisfy one of the conditions described in paragraph 17 will be
considered for publication under certain hardship conditions and other special circumstances. If the security
or the issuer of the security for which you are submitting a quotation representing an Unsolicited Customer
Order does not satisfy any of the conditions set forth in paragraph 17, please state the reasons we should
publish your unsolicited quotation in this case. OTC Markets, as a matter of policy, does not believe that
the Unsolicited Quote Exemption should be used to circumvent the FINRA Form 211 process.



One such exception to the rule is the "Unsolicited Customer Order" exception. To avail itself of this exception to SEC
Rule 15c2-11, a FINRA member firm must ensure that the quotation published or submitted: (1) is solely on behalf of a
customer; (2) represents the customer's indication of interest; and (3) does not involve the solicitation of the customer's
interest.



These exceptions are being removed, that is the point, there must be current information relied upon to keep the Form 211. The broker dealers have used exemptions and exceptions on "dark" securities, in particular the "piggyback" exemption has been used, as long as quotation exist for at least 4 days a broker dealer my quote that security. that is why when the SEC suspended a security for 10 days the Form 211 dies and the exemption cannot be applied. however that hasnt stopped broker dealers from using unsolicited quotation to get around the lack of a Form 211. that is why you are now seeing this new rule that will take place.