Replies to post #190909 on DD Support Board and Research Team

[janice shell]

No. It isn't as if they could just post an annual report at OTC Markets, and the next day they'd be trading "normally" again.

They'd still have to regain compliance with Rule 15c2-11, and that would mean getting a Form 211 approved by FINRA. Like so many things, it's unclear how that will happen now. OTC Markets will be able to offer assurances that a company has posted "current information" at the OTCM site, but FINRA will still have to clear a Form 211.

OTCM wanted to be allowed to deal with all of that on its own, merely informing FINRA that everything was in order, but FINRA balked at that proposal.

So if a company whose stock is knocked to the Greys wants to make a comeback, it will have to deal with FINRA, and may find itself supplying additional information for some time.

That, at least, is how things seem to stand now. FINRA proposed a rule change of its own to the SEC in June; that explains more:

https://www.sec.gov/rules/sro/finra/2021/34-92139.pdf