NNLX must provide the info to otcmarkets.com by June 30th
then otcmarkets.com (the public for profit company that Finra and SEC allows to do these things) will examine the info provided by NNLX by Sept 28- presumably that will give otc enough time to notify NNLX of any shortcomings in the info provided by NNLX so NNLX can correct by Sept 28
You can see the apparent contradiction in the info below -the first paragraph requiring everybody update to pink current to be quoted
and the 3rd par which intimates some companies may still be quoted if satisfy the requirements for limited info company-previously they alluded to unnamed exceptions(to the mandate of current info) or they may have loosened the everybody must be pink current requirement somewhat based on feedback
pink 'limited info' companies must meet the current financial standards info every 6 months or less detailed financials every quarter
presumably OTC or FINRA or SEC is keeping the affected companies (including NNLX) up to date on this information/the changing landscape
affected companies will probably be given more info than provided by otc in these otc monthly newsletters-
as I've noted before a long told me years ago that NNLX had read the then 44 pages of regulations to upgrade from 'no info' to 'pink current' otc status.
I presume NNLX will upgrade to pink current, unless there is an exception that NNLX can qualify for to upgrade to limited info status-
the cost difference per year is 1250 extra for pink current otc "news and disclosure" (the companies filings otc reports on its otcmarkets.com site) plus the cost of a SEC qualifed attorney providing a letter per quarter certifying NNLX has (when these requirements are in effect) met the standard of current info provided-such attorneys are few outside of certain financial centers-so whatever they charge to review the info provided by NNLX and fill in the blanks in the form letter
I presume OTC will make further clarifications each month prior to Sept 28
from the otc:
The upcoming implementation of amended SEC Rule 15c2-11 will require that all companies quoted on our markets must disclose current information on a continuous basis, effective September 28, 2021.
Pink companies will need to update their disclosure to ensure they comply with the new requirements.
Alternative Reporting Companies and Bank Reporting Companies: OTC Markets has updated the Disclosure Guidelines for Alternative Reporting Companies to include all the information required under amended Rule 15c2-11. Companies must follow the Guidelines to be designated “Current Information” or “Limited Information” and remain publicly quoted.
International Reporting Companies – Companies that are current in their periodic disclosure and are listed on a Qualified Foreign Exchange that requires disclosure in English will remain in compliance and may continue to be publicly quoted. Other international companies seeking to ensure their ongoing compliance may publish their disclosure directly to OTC Markets for review.
Impacted Pink companies should provide the required disclosure to OTC Markets by June 30th. This will ensure that our Issuer Compliance Team has sufficient time to review and update market status for companies prior to the rule’s compliance date on September 28th. Securities that do not meet the Rule’s disclosure standard will have their public quotes removed from Pink as of the September deadline.
then otcmarkets.com (the public for profit company that Finra and SEC allows to do these things) will examine the info provided by NNLX by Sept 28- presumably that will give otc enough time to notify NNLX of any shortcomings in the info provided by NNLX so NNLX can correct by Sept 28
You can see the apparent contradiction in the info below -the first paragraph requiring everybody update to pink current to be quoted
and the 3rd par which intimates some companies may still be quoted if satisfy the requirements for limited info company-previously they alluded to unnamed exceptions(to the mandate of current info) or they may have loosened the everybody must be pink current requirement somewhat based on feedback
pink 'limited info' companies must meet the current financial standards info every 6 months or less detailed financials every quarter
presumably OTC or FINRA or SEC is keeping the affected companies (including NNLX) up to date on this information/the changing landscape
affected companies will probably be given more info than provided by otc in these otc monthly newsletters-
as I've noted before a long told me years ago that NNLX had read the then 44 pages of regulations to upgrade from 'no info' to 'pink current' otc status.
I presume NNLX will upgrade to pink current, unless there is an exception that NNLX can qualify for to upgrade to limited info status-
the cost difference per year is 1250 extra for pink current otc "news and disclosure" (the companies filings otc reports on its otcmarkets.com site) plus the cost of a SEC qualifed attorney providing a letter per quarter certifying NNLX has (when these requirements are in effect) met the standard of current info provided-such attorneys are few outside of certain financial centers-so whatever they charge to review the info provided by NNLX and fill in the blanks in the form letter
I presume OTC will make further clarifications each month prior to Sept 28
from the otc:
The upcoming implementation of amended SEC Rule 15c2-11 will require that all companies quoted on our markets must disclose current information on a continuous basis, effective September 28, 2021.
Pink companies will need to update their disclosure to ensure they comply with the new requirements.
Alternative Reporting Companies and Bank Reporting Companies: OTC Markets has updated the Disclosure Guidelines for Alternative Reporting Companies to include all the information required under amended Rule 15c2-11. Companies must follow the Guidelines to be designated “Current Information” or “Limited Information” and remain publicly quoted.
International Reporting Companies – Companies that are current in their periodic disclosure and are listed on a Qualified Foreign Exchange that requires disclosure in English will remain in compliance and may continue to be publicly quoted. Other international companies seeking to ensure their ongoing compliance may publish their disclosure directly to OTC Markets for review.
Impacted Pink companies should provide the required disclosure to OTC Markets by June 30th. This will ensure that our Issuer Compliance Team has sufficient time to review and update market status for companies prior to the rule’s compliance date on September 28th. Securities that do not meet the Rule’s disclosure standard will have their public quotes removed from Pink as of the September deadline.
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