The SEC is seriously limiting the Expert Market.
"The proposed OTC Expert Market has been officially denied by the Securities and Exchange Commission (SEC). Earlier this August, the SEC issued a decision on a proposed order that would provide conditional exemption from Rule 15c2-11 for specific broker-dealer quotation publications through an Expert Market. The suggested market would have been operated by OTC markets. OTC Markets has confirmed to Colonial Stock that the Expert Market will continue to operate in a limited fashion."
But there are bigger problems for SRNW.
FINRA Rule 6490 mandates the 15c filing for any non-SEC reporting company before its shares can be quoted publicly. This is a prerequisite before filing SEC registration statements like Form 10.
Even if a market maker was willing to sponsor a 211 for SRNW, broker-dealers would likely refuse to allow deposit and trading of the shares due to the shell's history.
The lack of a properly filed 15c means SRNW is not in compliance with FINRA rules, which is a fundamental requirement for any reverse merger transaction to be approved.
So based on the cumulative evidence across the search results, it does not seem plausible that SRNW could have filed a Form 10 to become an SEC reporting company without first properly filing the mandatory 15c2-11 with FINRA.
As you can see by reading the OTCM warning on SRNW.
""Warning! This security is eligible for Unsolicited Quotes Only
This stock is not eligible for proprietary broker-dealer quotations. All quotes in this stock reflect unsolicited customer orders. Unsolicited-Only stocks have a higher risk of wider spreads, increased volatility, and price dislocations. Investors may have difficulty selling this stock. An initial review by a broker-dealer under SEC Rule 15c2-11 is required for brokers to publish competing quotes and provide continuous market making.
After changes to Rule 15c2-11 a couple of years ago - the SEC has pretty much stopped all Custodianships because FINRA won't process a 15c and it makes those shells worthless.
IG
The First Casualty of Emotion is Reason.
