On another note... OTC Markets has acknowledged that there's a problem with its "Expert Market":
SEC Announcement on Expert Market Proposal
On August 2nd, the SEC Trading & Markets staff issued a notice stating that the SEC will not approve the proposed changes to the Expert Market.
This means securities of issuers that do not comply with the new Rule 15c2-11 disclosure requirements will not have proprietary market maker quotes in the Expert Market. Pink No Information stocks that shift to the Expert Market on September 28, will only be available for unsolicited quotes from brokers representing Limit Orders of investors not affiliated with the issuer.
That last line is quite sinister. Do they seriously plan to allow any No Info stock to trade with published quotes as long as somebody--an "investor", OTCM says comically--asks an MM to file to publish unsolicited quotations?
OTC Markets, as a matter of policy, does not believe that the Unsolicited Quote Exemption should be used to circumvent the FINRA Form 211 process.
That, of course, will be what ANYONE requesting that any of these junk stocks be quoted unsolicited is trying to do. And if OTCM allows it, which they obviously intend to do, they are also trying to circumvent the Form 211 process.