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To: Richard Phillips who wrote (2077)12/20/1999 10:19:00 AM
From: SCOOBEY-DO  Read Replies (1) | Respond to of 2136
 
Crosspost from the RB:

By: ToysRust
Reply To: None Saturday, 18 Dec 1999 at 3:14 PM EST
Post # of 19556


FYI-3 DAY RULE-15c-211. The new MM must submit the 15c-211 to NASD 3 days prior to being able to list quotes on the OTCBB so that the info can be reviewed.

We have been told that Mr. Porter has submitted the required paperwork to the MM to file the 15c-211. Lets pretend that it was sent on Wednesday. The MM files the 15c-211 on Thursday. That would mean that Tuesday or Wednesday would be the earliest that we could return to the OTCBB. Which is fine as far as Im concerned.

I do not know what paperwork has been filed when, but MAYBE Porter is waiting until NASD reviews and approves the paperwork before he is ready to release any concrete info. That way, when we get the word everything will be ready to go. Would you rather trade with the spread on the PINKS or the spread on the OTCBB? Both buyers and sellers would be best served to wait IMHO. The ruling info is below. Happy Holidays to ALL and go ALFN!!!!!ToysRust
B. Quotations subject to the Rule

1. The initial quotation for a covered OTC security

As indicated above, the Rule's requirements will apply at the time of discrete quotation events. Subject to the Rule's exceptions, the amendments will prohibit the first broker-dealer from publishing a priced or unpriced quotation for a covered OTC security in a quotation medium unless it has obtained and reviewed specified information about the issuer and the security. Further, this information will need to be submitted to the NASD, in accordance with the NASD's rules, at least three business days before the quotation is published. 42 There is one situation that "restarts" the Rule's requirements: following the termination of a Commission trading suspension ordered pursuant to Exchange Act Section 12(k), 43 the broker-dealer publishing the first quote, whether it is priced or unpriced, must comply with Rule 15c2-11. In essence, this is the way the Rule currently works.

We believe that the Rule should cover the first quotation as a means to assure that there is basic information about the issuer available to the marketplace before trading in the security begins and to alert regulators that trading in the security will be starting. The NASD uses Rule 15c2-11 submissions for surveillance and enforcement purposes and routinely provides copies of this information to the Commission.