This interminable splitting of semantic hairs over whether a 211 is needed reminds me of the debate over whether an AR-15 is an assault rifle or just a rifle for assault or an assault-style rifle. That debate does nothing to change whether or not the guns should be regulated and if so how. And this 211 back and forth does nothing to change the fact that there's a new process in place between SEC, FINRA, and OTC.
People might say firms no longer need a 211, but what we mean is that this part of the process has been simplified and can now be handled by OTC so that a 211 is no longer needed to be filed by the firm. We don't need a bunch of links to read every time we say informally that the firm no longer needs a 211. What we mean is that it no longer needs to be filed by the firm
Hopefully this explanation can help us avoid further tedious/tendentious harping on 211s?
I am obviously NOT an investment advisor.