The OTC Markets Adopts New Rules for Securities La
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As of January 3, 2013, the OTC Markets reduced the requirement that an issuer provide quarterly legal opinions for its reports. Issuers must now only provide an opinion from a securities lawyer one time annually. For issuers who provide an audit letter by a PCAOB registered auditor along with each Annual Report, an Attorney Letter is not required to qualify for the OTC Pink Current Information tier.
An opinion letter need only be provided to accompany the issuer’s annual report; it is not required for quarterlies.
source
http://www.occupyotcmarkets.com/2015/otc-mark...uirements/