Hey SS, see if this article helps. https://investorshub.advfn.com/boards/read_msg.aspx?message_id=158448572 I have actually read as much of the rule as I can stand. I'm not a lawyer so it's "tough sledding". In the end I concluded there is an 18 month exception for all changes in ownership. Not sure if that starts with a custodian - or not. Will only know for sure on Sept 29th. Then we will know what the Broker Dealers have concluded. And then after that we will know if the SEC agrees the Broker Dealers have gotten it right. If not, then suspensions could soon follow. Not sure about everyone else, but I am very curious to see how the rest of the year unfolds for the OTCM.