No, 15c2-11 filing is not by the companies but by the brokerages. Broker-dealers for these over-the-counter securities must demonstrate they have a reasonable basis for believing the issuer's information is accurate and reliable. And it has absolutely nothing to do with where and how a stock is listed and nothing to do with a ticker being PINK, ID, Expert etc. AS soon as MZ files the annual, EGYF would be OTCID since they filed already the management certification and otherwise are up to date. And most other OTC tickers I hold have already the OTCID listing since they filed quarterly, annuals, managm. cert. incl. those with no revenue, with terrible debt, tons of convertible notes, etc. EGYF has no issues other that "CEO" not filing the financials.
Market Data 
Markets 
AI
