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Re: TJG post# 4559

Wednesday, 10/08/2025 3:29:25 PM

Wednesday, October 08, 2025 3:29:25 PM

Post# of 4969
From a contact @ FINRA just so we have an idea.
Typical Timelines
Phase Description Average Duration
1. Market Maker Engagement Finding and retaining a sponsoring market maker 1–4 weeks
2. Preparation of the Form 211 Package Includes company background, financials, business plan, officer bios, share structure, and recent corporate actions. 2–6 weeks
3. FINRA Review Cycle FINRA reviews, issues comments, and requests clarifications or supplemental info. Multiple rounds are common. 4–12 weeks
4. Approval and Activation Once FINRA clears the filing, the ticker becomes Quote Eligible (Bid/Ask quotes reappear). 1–3 days after approval

Total Timeframe (Typical)
Best case: 6–8 weeks
Average case: 3–5 months
Problem cases: 6–12+ months (especially if the company has missing disclosures, regulatory issues, or prior caveats like shell risk or fraud flags)

A broker-dealer must agree to sponsor FDCT by submitting a Form 211 under Rule 15c2-11.

Examples of sponsoring market maker that often file Form 211s for OTC issuers include:

Spartan Securities Group, Ltd.
Wilson-Davis & Co.
J.H. Darbie & Co.
Caldwell Securities
Muriel Siebert & Co.
MCAP LLC
CIM Securities, LLC
BMA Securities
Corclear Securities, Inc.
Arque Capital, Ltd.

(Each of these above firms has handled 15c2-11 filings for OTC issuers particularly small caps and shells.)


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