To: rrufff who wrote (3465 ) 6/7/2008 4:01:26 PM From: creede Respond to of 5034 Thank you, rrufff. I could not have been more excited when I found it. Especially since the wording of "Pay to Play" or "Pay to File" would indicate, imo, that it something very well known in the market maker business - why else would they have a couple of slangs for the term? So now we add another dimension of difficulty for a pinksheet stock to overcome if they want to find a market maker to file a 15c2-11 - like the shareholders needed yet another hand held out that is getting shares for free! And so, looks like the 15c2-11 - which was supposed to be designed to protect us - can actually be used to hurt us if the CEO is not savey enough not to fall for this trap. re MM accounts - looks like we knocked out 2 birds with one stone. Here's some of what I really found to be juicy. Finally, the NASD warned members that "any arrangement whereby a member charges an issuer a fee for making a market or accepts an unsolicited payment from an issuer whose securities the member makes a market in raises serious questions under the anti-fraud provisions of the federal securities laws ." NTM 75-16. Staff also cites to NTM 92-50, published in October 1992, which is a comprehensive guide regarding procedures for compliance with SEC Rule 15c2-11 and Schedule H, Section 4 to the NASD By-Laws (now known as Marketplace Rule 6740).5 NTM 92-50 states, "A market maker cannot accept any form of compensation, including cash [or] securities . . . for the purposes of making a market, to cover out-ofpocket expenses for making a market, or for submitting an application to make a market in an issuer's securities." (emphasis added) . GB-ND creede