October 21, 2014
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SEC Proposes Amendments to Rule 15c2-11

The Securities and Exchange Commission (“SEC”) recently published a rule filing that proposes amendments to Rule 15c2-11 and has ramifications to the OTC Bulletin Board. On February 25, 1998, the SEC published Release 34-39670, requesting public comment on proposed amendments to Rule 15c2-11 under the Securities Exchange Act of 1934. Rule 15c2-11 governs the publication of quotations for securities that are traded in a quotation medium other than a national securities exchange or Nasdaq. The proposal was published in the Federal Register at 63 Fed. Reg. 9661 and is also available from the SEC Web site.

The proposals have three major components:

  1. require all broker-dealers to review information about the issuer when they first publish or resume publishing a quotation for a security subject to Rule 15c2-11, document that review, annually update the information if they publish priced quotations, and make the information available to others upon request;
  2. eliminate the existing piggyback provision, which permits broker-dealers to publish quotations for a security without filing a Form 211 if any other broker-dealer has published regular and frequent quotations for that security;
  3. change the information requirements for quotations for the securities of non-reporting issuers and the recordkeeping requirements when broker-dealers have electronic access to information about reporting issuers.
We encourage you to review the proposed amendments and provide your comments directly to the SEC. Comments must be received by the SEC on or before April 27, 1998. If you would like further information about the proposal, the SEC has identified the following attorneys as contacts in the Office of Risk Management and Control, Division of Market Regulation, at (202) 942-0772: Nancy Sanow, Alan Reed, Irene Halpin, Florence Harmon, Denise Landers, or Chester McPherson.


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