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blue dog

04/23/14 9:42 AM

#86253 RE: BigHeis #86250

I am not certain what you mean by first and second tiers:

I think that is the second tier piece. It does say all OTCQB must meet the minimum bid test at the first part then the second part kicks in to continue on the board otherwise they will be kicked to the Pinks.


The way that I read the new OTCQB policy, there is (1) a penny test, and (2) a schedule to roll out that penny test.

The rollout schedule applies differently to companies that are not listed as OTCQB as of April 30, 2014, and companies that are listed OTCQB as of April 30, 2014:

(a) new companies going onto OTCQB after April 30, 2014, must meet the penny test; but

(b) existing OTCQB companies face a rollout, which depends on when their fiscal year ends.

The earliest that an existing company must meet the penny test is July 31, 2014, and that applies only to existing OTCQC companies with fiscal years ending March 31, 2014. If an existing OTCQC company's fiscal year ends March 30, their compliance deadline in July 31, 2015:

Companies with a March 31 FYE will be the first group of current OTCQB companies subject to the new requirements and will be required to comply with the new OTCQB standards by July 31, 2014. The rollout will be complete when the last group of current OTCQB companies with a FYE of March 30 are required to comply on July 30, 2015.

http://www.otcmarkets.com/content/doc/otcqb-fact-sheet.pdf


So that single day (between March 30, 2014, and March 31, 2014) makes an entire year's worth of difference. SNEY is somewhere between those two boundaries, and its compliance deadline should be December 31, 2014 + 120 days (i.e., April 30, 2015).