On January 8, 2018, the OTC Markets Group issued a response letter to FINRA’s request for comments in which OTC Markets Group states that the “cumbersome operational processes around Rule 6432, and the related Rule 15c2-11 under the Securities Exchange Act of 1934 (SEA) unnecessarily impede capital formation by small issuers.”  The OTC Markets Group goes on to say that Rule 6432…

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