Section 4. Broker-Dealer Recordkeeping and Reporting Question 4.1: Do the recordkeeping and reporting requirements of Rule 13h-1 apply only to NMS securities?
NMS vs. Other OTC NASDAQ is the highest of four levels of over-the-counter (OTC) trading where companies must meet specific criteria of capitalization, profitability, and trading activity. Also, NASDAQ provides more comprehensive intraday trading information that is available for the lower levels of OTC stocks. Information includes last-sale prices, daily high and low prices, cumulative volume, and bid and ask quotes. Here, market makers must report actual transacted prices and share sizes within 90 seconds of the transaction. This requirement contrasts with the non-real-time reporting for non-NMS, lower tier OTC stocks.
The NASDAQ, while still a decentralized system for over-the-counter stock trading, is a virtual exchange with all the regulations, requirements, and safeguards that come with clearing houses. Other OTC markets have considerably fewer rules and safeguards.
OTC markets break down into three tiers, called the OTCQX, OTCQB, and Pink Sheets. Listing requirements decrease with each level. Also, all of these markets are less stringent than exchanges covered by the National Market System.
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