Update: "SHAREHOLDERS UPDATES: OTC Markets rules
Post# of 919
More on filing procedures and education 101 for OTC Markets and OTCIQ filings, corporate actions and DD criteria.
OK, the reason why I actually feel great , concerning these latest "conspiracy theories" , is very simple. If there EVER was a time that proves how "some" people just make up stories, and continue to "count" on folks NOT bothering with fact checking and /or simply are too lazy looking up on SEC and OTC Markets web page and "actually read!" the rules and regulations. Then here is MY quick note as to what is really happening!
So, what is the latest "hot topic"? Well, its the "Attorneys Agreement letter with OTC Markets". The latest "theory, and the "panic", "OH MY GOD! NO ONE CAN FIND THE LETTER!"
First of all, that letter is between OTC Markets and the Attorney. That's why its called : "Attorney's Agreement Letter with Otc Markets!". (and its filed ONLINE via a "DoCusign" system, that is between attorney and OTCIQ). This development, is an additional combination of new rules and new compliance criteria that is now introduced and implemented by the OTC Markets, and OTCIQ filing criteria. These rules and criteria as well as updated compliance requirements were for the most part dictated by regulatory agencies who monitor and are part of the approval process that companies have to go through each quarter, and year end filings. The agencies that I refer to are: SEC, FINRA , DTCC and of-course OTC Markets themselves and etc..... Now, lets examine the most recent events. While I was working with my attorney and management at, AURI Inc., Simon who is our attorney there, did not even know that OTC markets added several new rules to both the company's filing requirements and "authorized vendors requirements", such as CPA, PCAOB CPA'S , TRANSFER AGENTS AND OTHERS!.NOTE*** In the past, OTC Markets required attorneys to be first SEC approved, and then to file a request letter in order to be eligible to be "approved on OTC Markets as an approved OTC attorney". That letter sat in the attorneys file at OTC Markets.
Once approval was granted, said attorney would be published on OTC Markets approved attorneys list and the attorney could work for and "opine" on ANY and all companies that are trading on OTC Markets boards! However, now, OTC Markets require the same attorney's to "ANNUALLY" post an "Attorney's agreement letter with OTC Markets" , and do so for "EACH TICKER THAT THEY SERVICE". Now, in our example, Brian has filed 2 letters, one for SUTI, and one for PBHG. (Let me also dispel and squash another rumor /much debated and misleading accusation posted by "some of these bashers" " a company can hire and employ as many SEC and OTC Markets approved attorneys as they please. That decision (in our case), has more to do with a tremendous work load, Covid 19 challenges, and the fact that we are getting "multiple years" and filings caught up all at once and for 8 companies!. So now! Ladies and Gentlemen, the reason why you cannot locate the said "attorneys agreement letter with OTC Markets", is simply because its between those organizations, and have nothing to do with our company and our disclosures.
FINALLY: It seems that some of you misunderstood and possibly thought that the "letter in question", was the typical "attorneys' opinion letter as to the CURRENT status of the corporation". those are different letters. And that letter is opined and posted annually, by the corporate attorney, after he/she reviews all the corporate filings for that year, and "AFTER" all the comments and suggestions are addressed from OTC Markets own review of the same annual corporate filings.
So, all that I reported, in order to combat lies and false accusations by some "uneducated ,ignorant bashers", is the fact, that BRIAN filed HIS letters with OTC Markets. Therefore, speeding up the process to ensure that PBHG, and SUTI get updated to the "current status" ASAP!....
In closing, as I always say:"I'm not an attorney, CPA or wealth managements or consultant to any of you. " I represent companies that you may have invested in. I'm reviewed and scrutinized by many FEDERAL and STATE regulatory agencies, and so far, for the past 20 plus years, I have always been approved by them. I also recommend to read and do your own DD , and I also remind everyone that the details as far as rules and regulations can be VERY easily found on SEC, FINRA and OTC Markets official websites. SO PLEASE! DO at least "some" research , BEFORE you believe posted lies that are targeted to hurt our companies.
In the meantime, thank you for all your support, and please stay safe. As always, my contact information is posted, and I do respond to everyone as soon as I can."
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A very apposite motto for those who trade successfully in the OTC market..
All posts are my opinion - trade at your own risk.