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SooS416

05/08/19 1:34 PM

#83133 RE: BigBadWolf #83130

It doesn't matter, all entities whether OTC or NASDAQ are subject to Rule 144 which is what details restricted securities and vesting requirements

https://www.pillsburylaw.com/images/content/4/8/v2/483/RobbinsRule7012013.pdf

Rule 701(g)(3) provides that 90 days after an issuer becomes subject to the
reporting requirements of the Exchange Act, securities issued in a Rule
701 transaction may be resold pursuant to Rule 144 by a person who is not
an affiliate of the issuer in reliance on Rule 144, without compliance with
paragraphs (c), (d), (e) and (h) of Rule 144, and by affiliates without
compliance with paragraph (d) of Rule 144