Here are the OTCBB requirements
OTC Bulletin Board (administered by NASDAQ)
Financial Requirements : No minimum shareholder equity or income. Companies must be reporting companies, providing an annual report to shareholders, current in all its filings, and subject to SEC proxy rules.
Distribution and Size Criteria : No minimum number of shareholders or shares outstanding, other than having a sufficient number of shareholders and shares outstanding to allow a trading market.
SEC status : Listed companies must have completed a registration of the company or its securities and have reporting company status. Companies must be current in all their filings. New shell companies will not be granted a trading symbol.
Companies with securities quoted on the OTCBB are subject to periodic reporting of financial information to the SEC. Issuers who file with the SEC via EDGAR are not required to submit hard copy filings with the OTCBB or the NASDAQ. Unlike all other exchanges, stocks trading on the OTC Bulletin Board cannot be shorted.
