Perhaps. Part of the problem is that no one knows exactly what will happen. OTC Markets has asked the SEC to allow them to add all tickers that aren’t in compliance to their “expert market” which retail cannot trade, only brokers, MMs, and qualified investors. Currently, OTCM designates expert market tickers with a CE, which 95% of retail retails brokers can’t buy anymore. To remove a CE once these rules go into effect, officers will need to file to get current (of course) and also file a form 211 which takes time & money and has no guarantee of approval. OTC Markets has streamlined the 211 process with the new rules in anticipation of this, but it’s till not going to be easy. So whether tickers can just file fins and be automatically quoted again hinges on how the SEC actually enforces the rules and how OTC Markets chooses to designate tickers that aren’t in compliance. I have studied this extensively and spoken with shell custodians as well as lawyers.
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