The OTC Pink marketplace is divided into three tiers - Current Information, Limited Information, and No Information - based on the level of disclosure and public information provided by the company. There are no qualitative standards for OTC Pink companies beyond disclosure requirements. To maintain Current Information status, companies must provide annual and quarterly financial statements and reports through SEC filings or by posting them on the OTC Markets website. They must also pay annual and set-up fees to subscribe to the OTC Markets disclosure service. The next tier, Limited Information, has less stringent disclosure requirements and will be covered in an upcoming discussion.

1. OTC PINK Listing
Requirements
OTC PINK Listing Requirements, Laura Anthony Attorney- The OTC Pink, which includes
the highest-risk, highly speculative securities, is further divided into three tiers:
Current Information, Limited Information and No Information, based on the level of
disclosure and public information made available by the company either through the
SEC or posted on OTC Markets through its alternative reporting standard. There are no
qualitative standards beyond disclosure for OTC Pink companies, which include
companies in all stages of development as well as shell and blank check entities…

2. OTC PINK Listing Requirements
• The OTC Pink, which includes the highest-risk, highly speculative securities, is
further divided into three tiers: Current Information, Limited Information and No
Information, based on the level of disclosure and public information made
available by the company either through the SEC or posted on OTC Markets
through its alternative reporting standard. There are no qualitative standards
beyond disclosure for OTC Pink companies, which include companies in all stages
of development as well as shell and blank check entities.
• Companies with Current Information status on OTC Markets include both
companies that are subject to and current in their SEC Exchange Act reporting
requirements and either choose not to apply or do not meet all the requirements
for a quotation on the OTCQB; and companies that file current information on
OTC Markets in accordance with the OTC Markets Alternative Reporting
Standards.

3. OTC PINK Listing Requirements
• If the company is subject to and current in their SEC Exchange Act reporting requirements, they will satisfy
the financial reporting requirements for Current Information;
• If the company is not SEC reporting it must post certain financial information on the OTC Markets website
including annual financial statements, including a balance sheet, income statement, statement of cash flows
and notes to financial statements, for the previous two fiscal years or from inception if the company is less
than two years old;
• Audits are not required, but if financial statements are audited, the auditor report must be posted as well;
• If the company’s financial statements are not audited, an annual Attorney Letter must be posted within 120
days of fiscal year end – no attorney letter is required if the financial statements are audited
• The company profile page on OTC Markets must be current and accurate;
• In addition to financial statements, the company must file annual and quarterly reports with narrative
information and CEO and CFO certifications using a fillable form available through OTC Markets;
• The quarterly report and financials must be posted within 45 days of quarter end and the annual within 90
days of fiscal year end
• A company must file a Form 8-K if SEC reporting or submit a news release within 4 days of any of the 8-k
triggering events (including for example, entry into a material agreement; the acquisition or disposition of
assets outside the ordinary course of business; the sale of unregistered securities; and changes in officers,
directors or control shareholders).

4. OTC PINK Listing Requirements
• In addition, to maintain Current information status, a company must
subscribe to the OTC Disclosure & News Service with an annual fee of
$4,200 and a one-time set-up fee of $500.
• In the next LawCast in this series I will discuss the Limited Information
level of the OTC Pink marketplace.

5. OTC PINK Listing Requirements