BDB, looking at the OTCBB FAQ, is says FINRA sets the requirements and the only one is current financials.

What are the eligibility requirements for the OTCBB?
In order for a security to be eligible for quotation by a market maker on the OTCBB, the security must be registered with the Securities and Exchange Commission (SEC) or other federal regulatory authority that has proper jurisdiction (see below) and the issuer must be current in its required filings with such federal authority.

Domestic issues quoted on the OTCBB are limited to the following securities:

• securities of issuers that make current filings pursuant to Section 13 or 15(d) of the Securities Exchange Act of 1934 ("Act");


• securities of depository institutions that are not required to make filings under the Act, but file publicly available reports with their appropriate regulatory authorities;


• securities of registered closed-end investment companies; and


• securities of insurance companies that are exempt from registration under Section 12(g)(2)(G) of the Act.

Foreign issues and ADRs must be registered with the Securities & Exchange Commission (SEC) pursuant to Section 12 of the Securities Exchange Act of 1934.