Cache Inc (CACH)

[THall]

Maybe this will help

Prior to the amendments becoming effective in September 2021, under Rule 15c2-11, brokers seeking to begin quoting a security on OTC Link ATS must collect, review and maintain information concerning the company, including financial statements, a description of the business and other information that would allow investors to make an informed investment decision. The Rule currently does not require that any of this information be made publicly available. Rule 15c2-11 works in tandem with FINRA Rule 6432, whereby a broker must file a Form 211 and receive approval from FINRA before it can publicly quote or make a market in the security.

After FINRA approves the Form 211 and a market maker initiates a quoted market in the stock, other brokers can “piggyback” onto the original quote and publish proprietary quotations in the security with no further obligation to review information about the company. The result under the existing “piggyback exception” is that brokers are permitted to maintain a public market in securities of “dark” companies (i.e. those that are not providing regular, current disclosure to the market).