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janice shell

10/01/21 1:30 AM

#62106 RE: Bonjourno #62105

Sure they can. After all, they've been trading it since the fall of 2019. OTC Markets took the Expert Market online on 23 April 2019:

https://www.otcmarkets.com/files/EOD_Pricing_Specification_v1.7.pdf

Toward the end of the year, it ramped it up, adding more and more issuers. They were all Grey Market companies. The difference between the Greys and the Expert Market was that the latter featured electronic execution. While the "Expert" companies didn't--or weren't supposed to--have published quotations, thanks to much faster execution and better price discovery, they were much more liquid.

Back then and now, OTC Markets allows many--perhaps most--to be quoted on an unsolicited basis. That makes them pretty much the same as ordinary Pinks. Obviously that was NOT the SEC's intention when it implemented the amendments to Rule 15c2-11. Here's the form that needs to be filled out for a stock to trade with unsolicited quotes.

https://www.otcmarkets.com/files/unsolicited-quote-form-1514935916031.pdf

Note the part that says:

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.

Really?

I believe the reason brokers aren't trading these stocks is that they believe they need to follow the rules, as laid out in the amended Rule 15c2-11. Perhaps FINRA has communicated with them. We don't know. But it'll be very interesting to see how all this plays out.