Forms D are SEC filings; they have nothing to do with OTCMarkets. As I said, the SEC would like for all issuers doing Reg D offerings to file Forms D, but it isn't a hard and fast requirement, unless they're using Rule 506( c).
Companies must file Form D whether they are registrants or not. They also must file with each state in which they sell securities in. Most accept the Form D along with a fee.
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