I do believe you are correct. but Mr. Dalton hasn't addressed the Shell Risk status, I think it would deter some investors from investing in UNVC.
It is well worth reading.
From an attorney. https://securities-law-blog.com/2023/02/28/th...companies/
In September 2020, the SEC adopted a complete overhaul of the 15c2-11 rules, the new rules of which went into effect on September 28, 2021. From a very high level, the new 211 rules: (i) require that information about the company and the security be current and publicly available in order to initiate or continue to quote a security; (ii) limit certain exceptions to the rule including the piggyback exception where a company’s information becomes unavailable to the public or is no longer current; (iii) limit certain exceptions to the rule including the piggyback exception where a company becomes and remains a shell company for a period of 18 months; (iv) reduce regulatory burdens to quote securities that may be less susceptible to potential fraud and manipulation; (v) allow OTC Markets itself to evaluate and confirm eligibility to rely on the rule; and (vi) streamline the rule and eliminate obsolete provisions. For an in-depth discussion on the 15c2-11 rules, see HERE and HERE.
Importantly, the 211 rules contain special provisions regarding shell companies. The rule allows for broker-dealers to rely on the piggyback exception to publish quotations for shell companies for a period of 18 months following the initial priced quotation on OTC Markets beginning as of the effective date of the amended rules – i.e., beginning on September 28, 2021. In essence, a shell company is granted 18 months to complete a reverse merger with an operating business, or in the alternative, to organically begin operations itself. The 18-month period begins when a company falls into shell status. For companies that were a shell company on September 28, 2021, and remain a shell today, the time limit to retain 211 eligibility will expire on March 28, 2023 – one month from now.
It is well worth reading.
From an attorney. https://securities-law-blog.com/2023/02/28/th...companies/
In September 2020, the SEC adopted a complete overhaul of the 15c2-11 rules, the new rules of which went into effect on September 28, 2021. From a very high level, the new 211 rules: (i) require that information about the company and the security be current and publicly available in order to initiate or continue to quote a security; (ii) limit certain exceptions to the rule including the piggyback exception where a company’s information becomes unavailable to the public or is no longer current; (iii) limit certain exceptions to the rule including the piggyback exception where a company becomes and remains a shell company for a period of 18 months; (iv) reduce regulatory burdens to quote securities that may be less susceptible to potential fraud and manipulation; (v) allow OTC Markets itself to evaluate and confirm eligibility to rely on the rule; and (vi) streamline the rule and eliminate obsolete provisions. For an in-depth discussion on the 15c2-11 rules, see HERE and HERE.
Importantly, the 211 rules contain special provisions regarding shell companies. The rule allows for broker-dealers to rely on the piggyback exception to publish quotations for shell companies for a period of 18 months following the initial priced quotation on OTC Markets beginning as of the effective date of the amended rules – i.e., beginning on September 28, 2021. In essence, a shell company is granted 18 months to complete a reverse merger with an operating business, or in the alternative, to organically begin operations itself. The 18-month period begins when a company falls into shell status. For companies that were a shell company on September 28, 2021, and remain a shell today, the time limit to retain 211 eligibility will expire on March 28, 2023 – one month from now.
3
