Material Event Reporting on the OTCID Market for Non-SEC Reporting Issuers
On July 1, 2025, OTC Markets Group replaced its Pink Current Information tier with the new OTCID Market, a modernized disclosure platform aligning with SEC Rule 15c2-11. The OTCID Market (OTC Information Distribution) is now the recognized path for non-SEC reporting issuers to maintain current-information status and quotation eligibility. For background, see Pink Current Will Become OTCID on July 1, 2025.
Why OTC Markets Replaced the Pink Current Tier
- Improved Disclosure Quality – standardized filings under Rule 15c2-11.
- Integration with SEC Rule 15c2-11 – OTC Markets gained authority as a Qualified IDQS.
- Automated Data Integrity – structured data fields ensure accuracy.
- Tier Consolidation – unified OTCID transparency model.
- Market Credibility – enhanced investor trust through consistent reporting.
When Material Event Reports Are Required
Material Event Reports must be filed when developments could influence investor decisions. Common triggering events include:
- Changes in Control
- Mergers or Acquisitions
- Significant Financings
- Board or Officer Changes
- Material Asset Transactions
- Bankruptcy or Receivership
- Auditor Changes
- Regulatory or Legal Proceedings
- Corporate Actions (stock splits, name changes, re-domestications)
- Other Material Events
How to File a Material Event Report Through OTCIQ
Step 1 — Log in to OTCIQ at https://www.otciq.com/home using authorized credentials.
Step 2 — Select ‘Create New Report → Material Event’ under Disclosure & News.
Step 3 — Provide event title, date, and detailed narrative description.
Step 4 — Attach supporting documents such as agreements or resolutions.
Step 5 — Include Officer Certification signed by the CEO or CFO.
Step 6 — Submit and confirm public posting after OTC Markets review.
Timing and Best Practices
OTC Markets expects issuers to file reports promptly, ideally within four business days of occurrence. Best practices include maintaining an event calendar, coordinating with counsel, cross-referencing event disclosures in quarterly reports, and labeling all attachments clearly.
Consequences of Non-Compliance
Failure to file required Material Event Reports can result in loss of current-information status, downgrade to Limited or No Information, Expert Market placement, and possible FINRA quotation suspension. Learn more at https://www.securitieslawyer101.com/2025/how-the-otc-markets-expert-market-works-securities-lawyer-101/
Relation to FINRA and SEC Requirements
The OTCID Market operates under OTC Markets Group, but broker-dealers remain subject to FINRA Rules 6432 and 6490. See https://www.finra.org and OTC Markets Direct – Bypassing the Sponsoring Market Maker Under SEC Rule 15c2-11
How OTCID Aligns with Going Public Strategies
Accurate OTCID reporting supports future disclosures in SEC filings and uplisting efforts. Related articles:
Form S-1 Registration Statements – What Companies Need To Know About Form S-1 & Going Public
Direct Public Offerings in 2025
Rule 144 Legal Opinions and Legend Removal Q&A
Key Resources
OTC Markets Reporting Guidelines
FINRA Corporate Actions Portal
SEC Rule 15c2-11 Final Release 33-10842
Conclusion
The OTCID Market replaces Pink Current Information as the primary disclosure platform for non-SEC reporting issuers. Timely, transparent Material Event Reports filed through OTCIQ are essential to maintain quotation eligibility and investor confidence. Hamilton & Associates Law Group assists issuers in preparing and reviewing OTCID Market disclosures in compliance with Rule 15c2-11.
If you have any questions about your OTC Markets disclosure requirements or would like to speak to a Securities Attorney, Hamilton & Associates Law Group, P.A. is ready to help. Our Founder, Brenda Hamilton, is a nationally known and recognized securities attorney with over two decades of experience assisting issuers worldwide with going public on the Nasdaq, NYSE, and OTC Markets. Since 1998, Ms. Hamilton has been a leading voice in corporate and securities law, representing both domestic and international clients across diverse industries and jurisdictions. Whether you are taking your company public, raising capital, navigating regulatory challenges, or entering new markets, Brenda Hamilton and her team deliver the experience, strategic insight, and results-driven representation you need to succeed.
To speak with a Securities Attorney, please contact Brenda Hamilton at 200 E Palmetto Rd, Suite 103, Boca Raton, Florida, (561) 416-8956, or by email at [email protected].
Hamilton & Associates | Securities Attorneys
Brenda Hamilton, Securities Attorney
200 E Palmetto Rd, Suite 103
Boca Raton, Florida 33432
Telephone: (561) 416-8956
Facsimile: (561) 416-2855
www.SecuritiesLawyer101.com
