The SEC’s Proposed Changes to Rule 15c2-11
The Securities and Exchange Commission (SEC) published on September 25th its proposed changes to Rule 15c2-11. Officially tiled “Publication or Submission of Quotation Without Specified Information.” A version of the proposed changes to Rule 15c2-11 as published in the Federal Register can be found here: Federal Register Version. Those who are wishing to submit comments to the SEC regarding the proposed rule changes have until December 30th, 2019 to do so.
What is Rule 15c2-11
For those who are unfamiliar with Rule 15c2-11, it is essentially the rule that specifies what information a broker/dealer must have in order to trade Over the Counter (OTC) securities. The information contained in a 15c2-11 disclosure package is submitted to FINRA for review and approval, prior to the initiation of trading in a company’s securities. Upon approval, FINRA will then issue a ticker symbol for a Company’s securities. It also contains exemptions that allow for other broker/dealers to easily make a market in a company’s securities once FINRA has approved them for trading. This is known as the “piggy back exemption“.
Please Read the Proposed Changes to Rule 15c2-11
We are recommending that everyone who is active in the Over the Counter Market, the OTC, take a few minutes to read the proposed changes to Rule 15c2-11. This includes investors, traders, private and public company officials, as well as lawyers and accountants who provide services to either public companies or those looking to potentially become public. For those who wish to do so, they may download a pdf copy of the proposed rule changes here: Proposed Changes.
Please Submit Comments
Additionally, we are urging everyone to submit comments to the SEC regarding the proposed changes to Rule 15c2-11. We feel that the proposed changes to Rule 15c2-11 will be very damaging to the OTC Market. We feel that the proposed changes to Rule 15c2-11 will also greatly reduce the number of companies that are able to uplist from OTC Market to an exchange, such as the NASDAQ or New York Stock Exchange. Additionally, we feel that the proposed changes to Rule 15c2-11 will make it much more difficult for small companies to raise capital. This will ultimately hurt the economy over a long period of time. There have already been a large number of comments submitted to the SEC on these proposed changes. A link to those comments is as follows: https://www.sec.gov/comments/s7-14-19/s71419.htm
How to Submit Comments on the Proposed Changes to Rule 15c2-11
The SEC has posted information on how to submit comments on the following page: https://www.sec.gov/rules/submitcomments.htm When submitting comments to the SEC, please note that the file number is: S7-14-19. Comments may be submitted by the following methods:
- Online Form: The online form may be accessed by clicking on the following link: https://www.sec.gov/rules/proposed.shtml then scroll down to September 25th, and click where it says “Submit Comments to on S7-14-19“. This will take you to the online form to submit comments on the proposed rule changes to 15c2-11. You may include an attachment with your online comment submission. Our apologies for not being able to provide a direct link to that page. Despite our best efforts we could never get the link to actually work.
- Email: You may email your comments to the SEC via. email address: email@example.com The subject line of your message should include S7-14-19 in the subject line of your email. You may attach a document to your email. The SEC requests that you specify the format of the document or software used (e.g., PDF, Word Perfect, MS Word, ASCI text, ect.) to create the attachment.
- Paper: If you would like to submit your comments in paper format, please submit three (3) copies to:
Securities and Exchange Commission
Att.: Vanessa Countryman, Secretary
100 F Street NE
Washington, DC. 20549-0609
Each copy must list the “File number S7-14-19”
Please Check Back with US
Coral Capital Partners will be submitting comments on the proposed changes to Rule 15c2-11 within the next couple of weeks. We will post our comments on line for everyone to review. Additionally, we will be publishing additional blog posts supporting our positions in the comments we submit to the SEC. Again, please take some time to review the proposed rule changes to 15c2-11, as well as the comments that have already been submitted, and submit your own comments to the SEC. We view this as a very important issue not to be taken lightly.
If you have any questions about the above blog post, please feel free to visit our web site, www.dtc.coralcapital.com and check out what we have to offer. Feel free to contact us if you have any questions. We can be reached at 404-816-9220 and are always willing to speak with you.
About Coral Capital Partners
Coral Capital Partners is an independent consulting and advisory firm focused on companies and participants in the lower and middle markets. We partner with our clients to provide cost effective solutions to real world issues and situations. Our experienced team brings a diverse set of skills that allows us to service a wide variety of needs. Our area of services and expertise focuses on bringing services and solutions to our clients that are normally only available to much larger firms. Coral Capital Partners, Inc. provides services to Investment Banks, Private Equity Funds, investors, and both privately held and publicly traded companies, as well as various stakeholders in those organizations. This has included international public companies with operations on three (3) continents to smaller privately held domestic companies. Our experience in the areas of corporate advisory, due diligence reviews, and regulatory compliance allows for a cost effective and efficient solution to the issues at hand. Please feel free to contact our offices to see how we may be of assistance.