By the end of January, any positions held that are impacted by the Caveat Emptor designation will be set to liquidating transactions only and no opening transactions will be allowed for these securities. Any existing opening orders will be canceled but you may close out any open positions or continue to hold. You will not be allowed to add any new positions in these securities unless the Caveat Emptor designation is removed by OTC Markets Group.
You better check on that. Since Schwab bought TDA, their policies should be the same. Beginning this month TDA will only process liquidating orders for CE tickers. Here's the notice.