What is the Rule 144 Holding Period for SEC Filers Shown as Pink Sheets on OTCMarkets.com?

New Requirements for OTC Markets OTCQB Market Tier

In 2014, OTCMarkets.com tightened the requirements for Issuers seeking to become quoted on its OTCQB marketplace.  This has resulted in many fully reporting SEC filers appearing as Pink Sheets on OTCMarkets until they complete the new certification and meet the new $0.01 bid test.  In the meantime, how can you tell what the proper Rule 144 holding period is for these Issuers?

Rule 144 Holding Period Remains the Same Despite the OTCMarkets.com Change

The Rule 144 holding period for non reporting Pink Sheets is twelve (12) months, but for current SEC filers is only six (6) months, even if those SEC filers are shown as Pink Sheets on OTCMarkets.com.  This applies to all non-shell, current, fully reporting OTCQB issuers.

How To Tell if an Issuer is an SEC Filer on OTCMarkets.com

For this reason, when looking up ticker symbols on OTCMarkets.com it is necessary to determine whether or not a Pink Sheet is really an SEC filer.  This information is shown just under the Company name.   If the Issuer is a “true” Pink Sheet, it will say “Alternative Reporting” underneath the name, rather than “SEC Filer.”  To double-check, a shareholder can also do a search on the SEC.gov Company Filings page.

Shareholders with questions regarding Rule 144 opinion letters Issuers seeking to upgrade to OTCQB contact Matt Stout, securities lawyer at (410) 429-7076 or mstout@otclawyers.com.

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