Is a Pink Current Issuer “Fully Reporting” Under Rule 144?

Current Public Information Under SEC Rule 144

Yes, even though Pink Sheets are not “SEC reporting” a Pink Current Issuer on can be considered “fully reporting” under Rule 144.

One of the important elements of SEC Rule 144 is the “current public information” requirement.  Sometimes investors believe incorrectly that an Issuer needs to be an SEC Reporting company that is current in its 10-Q, 10-K and 8-K filings to be considered “fully reporting” under Rule 144.

OTC Markets Has Three Tiers of Pink Sheets

OTC Markets divides its Pink Sheet Issuers amongst several market tiers, depending on how current the Issuer is in its OTC Markets filings.

Pink Current Issuers Under the Alternative Reporting Standard

Pink Sheet Issuers that timely file all of their Quarterly Reports, Annual Reports, and Information and Disclosure Statements are listed as Pink Current.

The Pink Current market tier designation means that this Issuer satisfies the reporting requirements under the OTC Markets Alternative Reporting Standard.

Shareholders with restricted stock in OTC Markets Pink Sheet companies, including those in Pink Current, Pink Limited Information (Pink Yield Sign) and Pink No Information (Pink Stop Sign) can contact securities lawyer Matt Stout with questions about the process of depositing and selling restricted stock under SEC Rule 144.

Matheau J. W. Stout, Esq. drafts Rule 144 opinions for shareholders of OTC Bulletin Board (OTCBB), OTCQB, OTCQX and OTC Pink Sheet Issuers.   For more information on the process of clearing restricted stock, shareholders seeking 144 opinions or Rule 144 letters can contact Matt Stout at (410) 429-7076 or read more at

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