Securities Law, NYSE, NASDAQ & OTC Markets Listings & Compliance

OTC Markets Direct: Sponsoring Market Makers Bypassed Under Rule 15c2-11

The OTC Markets Group has transformed how companies access public quotations after the SEC’s 2021 amendments to Rule 15c2-11. Before the reform, a market maker had to submit FINRA Form 211 to initiate quotation for an issuer’s securities. Today, OTC Markets Group, Inc.—the operator of OTCQX, OTCQB, and OTC Pink—may conduct its own review of issuer information and determine compliance with Rule 15c2-11 without a sponsoring broker-dealer.

The OTC Markets Initial Information Review Process

Issuers seeking to quote securities on the OTC Markets can now approach OTC Markets Group directly through the OTCIQ Issuer Portal to begin an Initial Information Review. The process includes application submission, staff review, and coordination with FINRA, leading to a determination that the issuer’s information is current and publicly available.

Benefits of the Direct Review Pathway

• Bypass the sponsoring market maker and submit directly to OTC Markets.
• Accelerated review timelines are conducted internally by OTC Markets staff.
• Improved transparency through publicly posted issuer information.
• Reduced regulatory friction by minimizing FINRA procedural delays.
• Enhanced investor confidence through verified disclosure review.

Ongoing Disclosure Obligations

Issuers approved through the Initial Information Review must maintain current information. OTC Markets requires quarterly and annual updates under its Alternative Reporting Standard or under the issuer’s SEC filing obligations. Failure to maintain current disclosures may result in a demotion to the Expert Market.

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If you are seeking to quote securities on the OTC Markets or would like to speak with 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