Professional legal support to navigate the OTCIQ platform, satisfy Rule 15c2-11 requirements, and support the “Current Information” status that can be important for market visibility.
To maintain a compliant and active presence on the OTC Markets, issuers generally use the OTCIQ platform to provide the public with accurate and timely disclosures. Following the SEC’s amendments to Rule 15c2-11, the requirements for “Current Information” have become significantly more rigorous. A missing disclosure, an unverified profile, or the absence of a qualified Attorney Letter can result in OTC Markets flags or quotation limitations and may materially affect liquidity.
At Ishimbayev Law Firm, we provide a turnkey OTCIQ Disclosure Package. We assist with the preparation of initial and periodic disclosures, coordinate with your accounting team, and prepare or coordinate the Attorney Letter where applicable to support ticker visibility and a verified, professional corporate profile.
Drafting the comprehensive “Information and Disclosure Statement” required by OTC Markets Group, including business descriptions, management bios, beneficial ownership data, and share structure details.
Issuing the formal legal opinion, signed by qualified counsel, confirming that the company’s disclosures are sufficient, public, and meet the required standards—where an attorney letter is required for the relevant current-information path.
Conducting a targeted review of your financial statements and corporate history to assess Rule 15c2-11-related current-information issues and identify risks that may affect public quotation eligibility or Expert Market treatment.
Assisting with the administrative setup of your OTCIQ account, the Verified Profile process, and help make sure corporate identity materials are implemented consistently.
We understand the technical nuances of the SEC’s transparency rules. We help make the OTCIQ disclosures more complete, consistent, and defensible under the applicable disclosure framework.
Where an Attorney Letter is part of the process, broker-dealers and OTC Markets reviewers may look closely at the quality and consistency of the disclosure package. We prepare legal work product designed to support that review without overstating what any market participant will do.
We don’t just “fill out forms.” We work with you to draft disclosures that tell your company’s story clearly, stay within the anti-fraud framework, avoid overstatement, and support a more credible public profile.
Deadlines OTC Markets deadlines are unforgiving. We provide agile support so your quarterly and annual disclosures—and the accompanying Attorney Letters, where applicable—can be filed within the applicable windows to reduce the risk of “Stop” or “Yield” flags.
For companies that are not required to file with the SEC but wish to be on the “Current Information” tier of the OTC Markets, a qualified attorney may need to review the company’s disclosures and issue a letter stating that the information is public and sufficient. OTC Markets Group may require this letter for the applicable current-information path.
Rule 15c2-11 generally requires broker-dealers to have and review specified current issuer information before publishing or submitting quotations, unless an exception is available. If the OTCIQ package is incomplete, quotation eligibility and investor access may be limited, and Expert Market treatment may become a risk.
No. While we work closely with your auditors or accountants to help incorporate their data into the OTCIQ Disclosure Statement, the firm does not provide accounting or auditing services. We provide the legal framework, drafting, and the necessary legal opinions.
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