Subject: S7-2025-02 The regulatory rule that killed the OTC
From: Jason Kellerman
Affiliation:

Sep. 5, 2025

The OTC was experiencing the greatest climate in decades. Companies had ample time to get their affairs in order to be "pink current or ID" compliant without a chopping block deadline to get their filings out. This 15c2-11 rule threw a wrench into the workings of hundreds of companies that collectively generated tens of $billions in market value! You had a bolstered retail in a strong market.

All of these companies suddenly had the same problem, they had to be "pink current" by September 2021 or face expert market rendering them off limits  to U.S. retail. This overloaded otc markets ability to process every filing to be compliant on time.  When the rule went into effect, 100's of companies went to expert market and $Billions in market value  evaporated overnight, effectively crippling retail.

There's an opportunity here with the inevitable rate cut looming near. You can do away with this abomination of a rule,
15c2-11; and unlock the 100's of companies that met their fate September 2021. Doing this would regenerate the $Billions once lost to the OTC. Let's make the OTC; and its retail, great again!
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