Form 211’s have to be filed for free on behalf of the Sponsoring Market Maker but they get exclusivity for a certain time frame routing trades once re listed.
Yes, they do. Maybe back in the last century that was a real advantage, because Nasdaq issuers needed to have Forms 211 filed, too. But in the past 20 years, it hasn't really done much for them. Compiling the 211, and then answering questions from FINRA, can be a time consuming headache. AND if there're any misrepresentations in the information given them by the issuer, the MM can be held liable.
I think the vast majority of companies that need Forms 211 starting Tuesday will choose to have OTC Markets make a determination as to current information, and submit a "modified" Form 211 to FINRA.
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