Support your sponsoring market maker with a legally reviewed, FINRA-focused dossier designed to address SEC Rule 15c2-11 requirements and reduce friction in the OTC quotation process.
Under the SEC’s amended Rule 15c2-11, broker-dealers (market makers) generally may not publish or submit quotations for a security unless they have obtained, reviewed, and maintained specified current information about the issuer. Because market makers face their own regulatory obligations, their compliance departments can be careful and detail-oriented. If they have to hunt for your financial records, decipher a messy cap table, or guess your operational history, they may decline to move forward or ask for significant follow-up before a Form 211 process can advance.
At Ishimbayev Law Firm, we help reduce this regulatory friction. We build the 15c2-11 Public Information Dossier—a comprehensive, organized, and legally reviewed data package designed to support a market maker’s compliance review. We help assemble the information a market maker may need for a Form 211 submission.
Compiling the issuer information contemplated by Rule 15c2-11(b), including exact business descriptions, officer/director identities, and historical financial records.
Reviewing the compiled data for inconsistencies, “red flags,” or missing exhibits that could lead to FINRA comments, market-maker follow-up, or a decision not to proceed.
Organizing supporting documentation regarding non-affiliate share distribution, verifying securities exemption histories, and providing clear, auditable capitalization summaries.
Creating a highly structured, secure, and easily navigable data room formatted specifically to align with a broker-dealer’s internal compliance checklists.
Market makers generally need a clean, organized information package before they will spend time on a quotation process. By presenting a professional, attorney-vetted dossier, you make it easier for a broker-dealer to review whether it is prepared to sponsor a Form 211 submission.
FINRA staff may closely review your market maker’s Form 211 submission. We build your dossier anticipating common FINRA and market-maker questions—specifically regarding your “shell company” history and share issuances—reducing the risk of avoidable delays.
If current information is not available, quotation eligibility and investor access can be materially limited, including potential Expert Market treatment. The dossier helps organize the current-information record needed to support public-market visibility.
The data compiled in your 15c2-11 Dossier often forms an important foundation for your OTCIQ Disclosure Package and your Attorney Letter. We aim to build it carefully so the same core information can support related OTC Markets filings and disclosures.
The rule generally requires broker-dealers to obtain and review specified issuer information before publishing or submitting a quotation, unless an exception applies. This includes the exact name of the issuer, the address of its principal executive offices, the state of incorporation, the title and class of the security, the par value, the number of shares outstanding, the name and address of the transfer agent, a description of the business, and recent financial statements.
A registered broker-dealer (your market maker) must file the Form 211 with FINRA. The issuer (your company) cannot file it directly. The market maker relies on a current and supportable information package, including the materials in your 15c2-11 Dossier to justify this filing to FINRA.
Not necessarily. While audited financials or other specific financial-statement requirements may apply for higher tiers or certain reporting pathways, the baseline Rule 15c2-11 requirement (and the Pink Sheets Alternative Reporting Standard) may be satisfied in some cases with unaudited financials, depending on the issuer’s status, reporting standard, and applicable OTC Markets requirements.
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