Frequently Asked Questions, Investor Information

What is the Pink Sheets?
The Pink Sheets is a centralized quotation service that collects and publishes market maker quotes for OTC securities in real-time. Pink Sheets is neither a Securities and Exchange Commission (SEC) Registered Stock Exchange nor a Broker-Dealer.

What is the OTCQB?
The OTCQB is a market tier for OTC-traded U.S. companies that are registered and reporting with the Securities and Exchange Commission (SEC) or a U.S. banking or insurance regulator. OTCQB stocks are identified with an icon reading “OTCQB – U.S. Registered." OTCQB securities may also be quoted on FINRA’s OTC Bulletin Board. The OTCQB allows investors to easily identify registered and reporting companies traded in the OTC market regardless of where they are quoted. See OTCQB Fact Sheet

How do I get a quote for a Pink Sheets stock?
You can get a quote for any given security by entering a symbol in the input box on the left side bar located on every page of www.otcmarkets.com.

How often are quotes updated?
The quotes displayed on otcmarkets.com are continuously updated from 8:00 AM to 4:00 PM and are delayed at least 15 minutes. Market makers are able to update their quotes at any time during market hours.

If I cannot find a company on your Quote page, where else do I look?
You should try using the Symbol Lookup feature, located under the symbol input box, to make certain you are using a valid symbol. If you are using the correct symbol, but still get no results, then the security is not quoted on Pink Sheets. It is likely on the "grey market."

Why is there no quote for some securities?
There are several possibilities:

1) The security is not quoted on Pink Sheets. You can verify this by checking the Primary Venue for the stock. It will be listed on the individual quote page for the respective security. If it says "Grey Market", then no market maker is publishing a quote for this stock in the Pink Sheets; it is what is known as a grey market stock.

2) There is no inside market on Pink Sheets for the security. Pink Sheets website displays inside or best bid and ask information. The inside is a calculation of the best of all the bids and asks published by individual market makers in Pink Sheets. In order to calculate an inside market, there must be at least 2 priced bids and/or 2 priced ask quotes. There is no requirement for a market maker to publish priced quotes in Pink Sheets; they can publish unpriced quotes. If we cannot calculate an inside bid or ask, then N/A will appear in the Best Bid and Best Ask fields on the quote page of otcmarkets.com.

Where do I get real-time quotes for Pink Sheets stocks?
Real-time quotes are available for broker-dealers and individual investors through our OTCQuote.com website on a password-protected subscription basis. For more information on this product, visit our OTC Quote page.

Issuers may sponsor real-time Level 2 quotes on www.otcmarkets.com and on their corporate website for investors to view. If you are an investor in a Pink Sheets company without level 2 Quotes, you may want to contact the Company's IR department. Companies must be in Limited or Current Information for Level 2 quotes to appear.

How do the Pink Sheets differ from the OTCBB?
Pink Sheets and the OTCBB are competing quotation services for OTC securities. Pink Sheets is a privately owned company, while FINRA operates the OTCBB. Unlike the OTCBB, issuers do not have to be fully reporting companies with the Securities and Exchange Commission (SEC) to be quoted on Pink Sheets. The Pink Sheets' OTC Dealer provides market makers with dynamic tickers and quote montages and an electronic trade negotiation system, while the OTCBB does not provide this functionality.

Who regulates the Pink Sheets?
Pink Sheets is neither a Securities and Exchange Commission (SEC) Registered Stock Exchange nor a FINRA broker/dealer. Pink Sheets is considered a Non-exclusive Securities Information Processor and an Interdealer Quotation System, for which registration is not required under current securities laws. However, Pink Sheets quotation and trading system is only open to registered broker/dealers and those broker/dealers are subject to FINRA Rules and regulations regarding their conduct and use of the Pink Sheets. Issuers are subject to Federal and State securities laws.

What are the Pink Sheets' trading hours?
Pink Sheets follows regular market hours, from 9:30 AM until 4:00 PM ET. Pink Sheets follows the market calendar of the Nasdaq Stock Market and is closed on the days that Nasdaq is closed. The Quotation system is available from 6 am to 5 pm every business day. However, individual traders at a market maker control when the trader's quotes are open and firm.

Where can I get historical information on Pink Sheet stocks immediately?
The Pink Sheets' Library Research Service offers a variety of standardized and customized research reports for the Pink Sheet securities. For more detailed information about this service click here.

How do I stop getting SPAM and unsolicited faxes?
Pink Sheets does not send, participate in the sending, nor authorize any unsolicited communications to the public, whether it's by e-mail, fax or Messenger pop-ups. However, these promotions cause damage to the Pink Sheets' reputation and we will work to track down the senders to get them, at a minimum, to include legitimate opt-out procedures on their communications. We would appreciate it if you would forward a copy of the message you received to info@pinkotc.com in order to help us in our efforts. If your complaint is regarding unsolicited faxes, please include the security being promoted, and any other pertinent details in your email.

Since the sender is not affiliated with us in any way, we are unable to remove you from this mailing or fax list. However, you can email any complaints you have of unsolicited communications and stock promotions to the Securities and Exchange Commission at enforcement@sec.gov.

The Federal Communications Commission also has an online complaint form specifically for unsolicited faxes on their website at http://www.fcc.gov/cgb/complaints.html.

The reference to Pink Sheets or our website in the message you received does not mean it is being sent by, or at the direction of, Pink Sheets. Pink OTC Markets Inc. is a quotation service for OTC securities. Because www.otcmarkets.com provides quotes and other information on OTC securities, illegal stock promoters mention our website in Spam similar to mentioning www.nasdaq.com for information on a company that is listed on NASDAQ. We do not gain anything from this Spam. We do not trade stocks and we do not promote stocks, whether they are quoted on the Pink Sheets or an Exchange such as NYSE, or on NASDAQ. Our client is not the general public, only professional traders and institutional investors.

What is the best browser to use to view otcmarkets.com?
Internet Explorer, version 7.0 and up and Mozilla Firefox, version 2.0 and up.

How can I advertise on otcmarkets.com?
Please send an inquiry regarding advertising opportunities to info@pinkotc.com.


	ISSUER QUESTIONS

How does a company become quoted in the Pink Sheets?
To be quoted on the Pink Sheets, you need to find one market maker willing to quote your company's stock. Only SEC-registered broker-dealers (market makers) that are members of the National Association of Securities Dealers (NASD) can quote securities in the Pink Sheets. For more information, see: How Does a Company Become Quoted on the Pink Sheets?

How can I find a market maker to file a Form 211?
Pink Sheets cannot recommend specific market makers. However, market makers listed in our Service Provider Directory welcome potential issuers to contact them to discuss making a market in their company's stock. For more information on Rule 15c2-11 and the Form 211, see: What is Rule 15c2-11?

Are there any filing requirements with the Pink Sheets for the issuers?
Issuers are not required to register securities with the Securities and Exchange Commission (SEC), or be current in their reporting requirements to be quoted on the Pink Sheets. Nor are issuers required to file financial or other company information with the Pink Sheets. SEC Rule 10b-17 requires all issuers of publicly traded securities, including Pink Sheets securities, to notify the NASD at least 10 calendar days prior to the record date of any dividend or other distribution, stock split, reverse split, or rights or subscription offering.

What are the fees?
The Pink Sheets does not charge issuers a fee for being quoted on the service. Market makers are charged for each security in which they make a market in the Pink Quote system and are prohibited by FINRA Rule 2460 from accepting payment by an issuer or their affiliate for publishing quotes.

How do I get my company "delisted" from the Pink Sheets?
Because securities are not "listed" on the Pink Sheets, it is not possible for an issuer to "delist" them. The only way to remove a company from the Pink Sheets is for all of the market makers to stop quoting it. If your company's securities no longer actually exist, but are still being quoted, you should contact FINRA's Market Integrity Department at 866-776-0800 and provide them documentation to that effect. FINRA will investigate and, if appropriate, eliminate the trading symbol and advise the Pink Sheets. Pink Sheets will then remove the market makers quotations in this security.

How are symbols assigned?
FINRA assigns all OTC security symbols.

How do I get my trading symbol or company name changed?
You should contact FINRA's Market Integrity Department at 866-776-0800.

Who do I notify about a merger, stock split or other corporate action?
You should contact FINRA's Market Integrity Department at 866-776-0800. FINRA will then notify Pink OTC Markets of the changes.

How do I update my company's information on otcmarkets.com?
Complete the Company Information Update Form

Do financial statements have to be audited?
Current NASD rules do not require the financial statements of Pink Sheet issuers to be audited, but they should be prepared in accordance with GAAP or, for foreign issuers, in accordance with their home country's accounting standards.

How can I publish a news release or financial report on otcmarkets.com?
There is an annual fee of $3600, which permits subscribers to post unlimited Financial Reports throughout the year; there is a per release fee of $100 to publish news releases through the Pink Sheets News Service. A one-time $500 account verification and set up fee applies. To subscribe to this indispensable service, please download the Subscription Agreement and fax to 212-652-5920 or E-mail to issuerservices@pinkotc.com. For more information, see Pink Sheets News Service

What are the shareholder notification requirements?
Pink Sheets has no shareholder notification or shareholder approval requirements.

How do I halt trading in my company's stock?
Only the NASD or the SEC can halt trading in OTC securities. The NASD does not have the authority to halt trading for the dissemination of OTC issuer news.

How can I get a list of market makers in my company's stock?
You can request a list of market makers in your company's stock by sending an email to issuerservices@pinkotc.com.

What can an issuer do to restore the display of quotes for its securities on otcmarkets.com once they have been blocked for spam or promotional activities?
The issuer must provide certain disclosure to investors via the OTC Disclosure and News Service (accessed via http://www.otciq.com). The disclosure must comply with Pink OTC Markets' requirements for the Current Information tier. This tier requires disclosure pursuant to Pink OTC Markets' Guidelines for Providing Adequate Current Information (PDF), as well as Pink OTC Markets' Guidelines for Attorney Letters. Pink OTC Markets, at it's discretion, may continue to temporarily block the dissemination of quotes for securities of companies that have provided the required disclosure if we continue to receive complaints about spam or other unsolicited communications promoting the issuer's stock.

Alternative Reporting Standard FAQs

Where can I find the Guidelines for Current Information and for Attorney Letters?

This information is available on the OTC Guide on www.otcmarkets.com. These documents can also be accessed via the links below:

How does an issuer create a document pursuant to the Guidelines for Current Information?

The guidelines are meant to serve as an instructional document to Issuers and are not fillable forms. As such, the Issuer must create their own Disclosure document, pursuant to these Guidelines, and follow the Guidelines format closely with each item addressed.

May I fax, e-mail, or mail documents for Pink OTC Markets to verify that they meet Current or Limited Information requirements?

No. Documents must be posted through the OTC Disclosure and News Service, as financial reports, in PDF format. When posted, an automatic alert is generated to Pink OTC Markets and documents are checked in the order that they were received. To subscribe to the OTC Disclosure and News Service, you can submit an Issuer Services Agreement to the Issuer Services department either via fax to 212-652-5920 or email to issuers@pinkotc.com.

What document types trigger the report review alerts to Pink OTC Markets’ Issuer Services department?

“Initial Company Information and Disclosure Statement”, “Annual Report”, “Quarterly Report”, “Interim Report”, “Semi-Annual Report” and “Attorney Letter with Respect to Current Information” report types trigger these alerts. Documents posted as Supplemental Information are not considered as valid financial report types for review for a company to move to either Current or Limited Information.

How do I incorporate by reference documents that are either posted elsewhere through the OTC Disclosure Service, on the SEC’s EDGAR system, or attached to my disclosure statement?

The reference must (i) clearly explain where the incorporated document(s) can be found and (ii) include a clear cross-reference to the specific location where the information requested by any particular item can be found in the incorporated document(s). Direct links to such documents may be provided as well.

What are the requirements for the Limited Information tier for companies who follow the Alternative Reporting Standard?

The minimum requirement is a financial report, posted through the OTC Disclosure Service, that contains a balance sheet, income statement, and total number of shares outstanding. This information must be for a period end date within the past six months. Financial reports do not need to be audited but must follow US GAAP. The number of outstanding shares must be in the financial report even if the information is updated on the Company Info tab on www.otcmarkets.com.

What are the requirements for initially getting to the Current Information tier for companies who follow the Alternative Reporting Standard?

Issuers must post an Initial Company Information and Disclosure Statement pursuant to Section One of Pink OTC Markets Guidelines for Providing Adequate Current Information (including financials for the most recent period end and previous two years), as well as an Attorney Letter following Pink OTC Markets Guidelines for Attorney Letters with Respect to Adequate Current Information. A signed Attorney Letter Agreement along with a copy of the attorney’s identification must be on file with Pink OTC Markets in order for the Current Information review to begin.

How does a company maintain Current Information through the Alternative Reporting Standard?

A company must post Quarterly Reports, following Section Two of Pink OTC Markets Guidelines for Providing Adequate Current Information, within 45 days of the quarter end, and Annual Reports, following Section One of the Guidelines, within 90 days of the fiscal year end. The company must also post Attorney Letters every quarter no later than 30 days after the due date for the Quarterly or Annual report.

Which Section of the guidelines does a company follow if the company wants to return to the Current Information tier once it has fallen to the Limited Information tier?

If a company has previously qualified for the Current Information tier within the past year, they may follow Section Two of the Pink OTC Markets Guidelines for Providing Adequate Current Information for Quarterly Reports. If it has been more than one year since the company was in the Current Information tier, the company must follow Section One of Pink OTC Markets Guidelines for Providing Adequate Current Information. Annual Reports must always follow Section One.

Can SEC Reporting companies follow the Alternative Reporting Standard to upgrade their OTC disclosure tier?

No. The tier for SEC-Reporting issuers is tied directly to the timeliness of their filings through the EDGAR system. The OTC Disclosure and News Service should not be considered an alternative to a reporting company’s SEC filing requirements. When a company deregisters via a Form 15 filing, their OTC disclosure tier is then determined by prior SEC filings and/or filings through the OTC Disclosure Service.

What is meant by the statement in paragraph 11 of the Attorney Letter Guidelines that counsel has "personally met" with management and a majority of the directors of the Issuer?

This statement describes the process used by competent counsel to perform the work necessary to submit an honest and reliable letter with respect to the issuer's disclosure ("Information") posted through the OTC Disclosure and News Service. This process requires counsel to assist the issuer by participating directly in drafting the Information required under Pink OTC Markets' Guidelines for Providing Adequate Current Information. In drafting this disclosure, the attorney will examine the evidence that supports each material statement made in the Information. Some of this evidence will be physical or documentary, while other evidence will consist of oral statements made to the attorney by executive officers who participated in or directed the events described in the Information. We believe that it is essential for the attorney to interview these officers personally to confirm the material facts described in the Information and clear up discrepancies in the evidence at hand. The attorney will then discuss the Information with the members of the issuer's board of directors to confirm and correct the disclosure, where necessary, so that it is a correct statement of all material facts regarding the issuer and its securities.

These tasks cannot be performed adequately unless the attorney has actually met "face-to-face" with executive management, including those persons actively involved in the matters described in the Information, and a majority of the Board of Directors. A personal meeting enables the attorney to assess the demeanor and credibility of these "witnesses" and supports, or in some cases, raises doubts, as to their testimony and recollection of events. It is also our experience that people are more candid when discussing matters with persons they have personally met.

Actual discussions regarding the matters disclosed in the Information can take place by telephone, email or other mediums, provided that the attorney on prior occasions has actually met face-to-face with each member of the issuer's executive management and a majority of the board of directors, and on the basis of those meetings, believes that these other mediums of communication will be adequate to confirm the reliability of the Information.

When does the Attorney Letter need to include Exhibit B of Pink OTC Markets Guidelines for Attorney Letters with Respect to Adequate Current Information?

Attorney Letters need to include Exhibit B (Items 14 & 15 of the Attorney Letter guidelines) when a company is flagged with Caveat Emptor because of promotion.

How many times per Quarter or Annual Report period can an Attorney Letter be posted to be considered for Current Information?

Pink OTC Markets relies on the attorney to thoroughly review an issuer’s disclosure prior to writing an Attorney Letter which clearly states that the information provided by the issuer on otcmarkets.com complies with the Pink OTC Markets Guidelines for Providing Adequate Current Information. If the company does not qualify for Current Information after an Attorney Letter is submitted, Pink OTC Markets will generally work with an issuer and their attorney to explain what information is missing or inadequately disclosed and conduct a secondary inspection once a new Attorney Letter is posted. At this point, if information is still missing or inadequate, Pink OTC Markets will not consider further Attorney Letter submissions until the next quarter or fiscal year end.


	INVESTOR QUESTIONS

What types of companies are quoted on Pink Sheets?
There are a wide variety of companies quoted on Pink Sheets. There are small companies that cannot or do not wish to meet the listing requirements of the exchanges; there are many large foreign issuers that are listed on an exchange in their home country but traded OTC in the US market (often because their financial statements are not prepared according to GAAP, which is a requirement for US listing); many Pink Sheets companies were formerly listed on an exchange and fell below the required standards for listing; due to the increased compliance costs associated with the Sarbanes/Oxley legislation, some listed companies have voluntarily delisted from exchanges and chosen to be traded over-the-counter; and there are a number of banks and other issuers that are thinly traded and so choose not to go to the expense of listing on an exchange.

Why isn't my security trading today?
There are many thinly traded stocks on Pink Sheets that are not traded every day.

How do I trade Pink Sheets stocks?
You must open an account with a broker to trade Pink Sheets stocks. The Pink Sheets itself is not a broker and does not provide a trading service to investors. For more information on trading Pink Sheets stocks, see: How to Buy or Sell Pink Sheets Stocks.

Why don't I see my order in the quotes?
Pink Sheets securities are not subject to Limit Order Display requirements. A market maker is not required to reflect a customer's order in its published quotation.

Why hasn't my order been executed?
You need to ask your broker this question. Brokers hold customer orders in their proprietary order books and only they can tell you specifically why it has not yet been filled. Possible explanations include: the order may not yet be marketable or if it is/was marketable, other customer orders at the same price may have been in the order book longer than yours and gotten executed first.

What does "Q" mean after a stock symbol?
In the fifth character of a symbol, "Q" means the issuer of the security is involved in bankruptcy proceedings.

How can I get the short interest for a Pink Sheets stock?
FINRA rules require that market participants report their short interest in non-Nasdaq OTC securities every 15 days. In order to access short interest data, please visit the following link to our website: http://www.otcmarkets.com/pink/marketactivity/short_interest.jsp.

How can I get a list of stocks by industry, company type or price range?
This information is not currently available. We are planning a future enhancement to www.otcmarkets.com that will permit users to search for securities based on these types of criteria. The statistics that we do currently track are available in the Trading Statistics section of our website.

What happened to my shares when the company was delisted?
If your stock was delisted from another market and is now quoted on Pink Sheets, nothing has changed with the shares themselves. You are still the registered owner of the securities and can trade them. You should check with your current broker to make certain that they will trade Pink Sheets stocks. If not, you will need to locate a broker that does trade Pink Sheets stocks. There is a list of some of these brokers at the bottom of the page in How to Buy and Sell Pink Sheet Stocks.

Why is the company contact information for a company on otcmarkets.com missing or inaccurate?
Pink Sheets issuers are not required to maintain current address or contact information with Pink Sheets. Pink Sheets does not have a listing agreement with its issuers and no other mean of compelling companies to provide this information to us, although many do so voluntarily. Pink Sheets has a relationship with the broker/dealers that quote the stocks, not with the issuers of the stocks themselves.

How can I get a list of new companies and IPOs?
Pink Sheets is only for seasoned securities; there are no IPOs in this market. You can get a list of securities that are new to Pink Sheets for the previous 7 days at the Market Data section of our website.

What happens when trading in a Pink Sheet security is suspended by the SEC?
SEC suspensions last 10 days for OTC securities. When a security is suspended, Pink Sheets removes all market makers and their quotes from the system and displays a "Halted/Suspended" message. After 10 days, market makers may re-enter the stock if they comply with Rule 15c2-11, which requires filing a new From 211, which must include the issuers' current financial information.


	MARKET MAKER/TRADER QUESTIONS

Do I still have to report trades to the NASD?
Yes, you are responsible for reporting trades through ACT. Pink Sheets offers a number of services that enables you to automate the reporting process. You can get FIX drop copies messages to integrate into your in-house systems, we can deliver drop copies to a third party such as Brass or we can submit drop copy executions directly to ACT on your behalf.

What is Rule 15c2-11?
Securities and Exchange Act of 1934 (Exchange Act) Rule 15c2-11 governs the submission and publication of quotations by brokers and dealers for certain non-Nasdaq over-the-counter equity securities. Specifically, the rule applies to a broker/dealer's initiation or resumption of quotations for such securities in any inter-dealer quotation medium, including the OTC Bulletin Board and the Pink Sheets. Pursuant to the rule, brokers and dealers are required to review and maintain specified information about the issuer of the security before publishing a quotation for that security. See complete text of Rule 15c2-11. Get a copy of the Form 211.

What is the piggy-back rule?
It means that a security is piggyback eligible under Rule 15c2-11. Market makers can quote the stock immediately without being required to file a Form 211.

Do I have to file a Form 211 for a New York Stock Exchange or American Stock Exchange delisted security?
Yes. Prior listing on NYSE or AMEX does not exempt a Market Maker from filing. However if the security was quoted on the Pink Sheets prior to the delisting, it may be already "piggyback" eligible.

The following interpretations of NASD Rules regarding Firmness of Quotations and Best Execution were provided by NASD Regulation in a letter to Pink Sheets dated April 28, 1999.

Do you post executions on the system?
No, the OTC Dealer does not post executions. For OTC equity securities, trades are reported to the NASD via the ACT system. In OTC bonds, there is no trade reporting facility, so no one sees a completed trade except you and your counter-party.

If I want to leave my desk for a little while and don't want to close my markets, is it possible to keep them firm?
Yes, you may temporarily exit the system without affecting your markets, however you are still liable under NASD Rules to trade at your published prices if your quotes are open.

What are the quoting requirements for the Pink Sheets?
You must be a FINRA-registered broker/dealer.

How do I withdraw from a Pink Sheet stock?
Users of the OTC Dealer can withdraw any quotes at any time using the "withdraw quote" command.

My quote has the best price, yet it does not show on the inside?
The Inside quote is calculated using only the quotes of traders who have opened their positions. Every trader has to open and close his/her markets every day.

What does the small "c" in front of the MMID mean?
It means that the trader has closed his/her markets and the quote is not considered firm. Closed quotes are not used to calculate the inside market.

Are the priced quotes in the Pink Quote system considered firm by FINRA rules?
NASD Rule 3320 provides that no member shall make an offer to buy from or sell to any person any security at a stated price unless such member is prepared to purchase or sell, as the case may be, at such price and under such conditions as are stated at the time of such offer to buy or sell. IM-3320 provides further that

[m]embers and persons associated with members in the over-the-counter market make trading decisions and set prices for customers upon the basis of telephone and wire quotations as well as quotations in the National Quotation Bureau sheets. In some instances a dealer's quotations, purportedly firm, are, in fact, so qualified upon further inquiry as to constitute "backing away" by the quoting dealer. Further, dealers who place quotations in the sheets have been found to be unwilling to make firm bids or offers upon inquiry in such a way as to pose a question as to the validity of the quotations originally inserted. Such "backing away" from quotations disrupts the normal operation of the over-the-counter market.

Members, of course, change inter-dealer quotations constantly in the course of trading, but under normal circumstances where the member is making a "firm trading market" in any security, it is expected at least to buy or sell a normal unit of trading in the quoted stock at its then prevailing quotations unless clearly designated as not firm or firm for less than a normal unit of trading when supplied by the member. . . (emphasis added).

Accordingly, for purposes of compliance with NASD Rule 3320, unless designated as a non-firm quotation by the broker-dealer or by the rules of the quotation system, any priced order to purchase or sell a security would be considered a firm quote and the member would be expected to execute that order at its published quotation size.

If a trader's market changes, what amount of time is considered allowable before the trader updates his or her price?
Although the SEC firm quote rule, Rule 11AC1-1(c), does not apply to transactions in OTC eligible securities, its provisions and exceptions should be considered in providing guidance and responding to this question. SEC Rule 11Ac1-1(c) provides that a market maker must execute an order "presented" to it at a price at least as favorable as its published quotation up to its published quotation size. Exceptions to Rule 11Ac1-1 exist only if: (1) the market maker revises its quoted price or size prior to the order being presented; or (2) the market maker has effected or is in the process of effecting a transaction at the time an order is presented and immediately upon completion of that transaction communicates a revised quotation (the trade ahead exception). A trade-ahead exception for trades that are reported after the presentment of an order will not be permitted if a market maker executes a trade and changes its quote absent proof, such as the time of order entry, that the market maker was in the process of executing the order prior to presentment of the order and the market maker immediately updated its quote subsequent to the execution. These same concepts also apply to members' responsibilities under Rule 3320 with respect to quotes and transactions in OTC equity securities.

What would constitute "backing away" by dealers in the Electronic Pink Sheets?
Backing-away occurs when a member firm fails to execute an order "presented" to it at a price at least as favorable as its published quotation up to its published quotation size and no exception from the firm quote rule applies.

Will Rule 6750 apply for minimum sizes in OTC Equity Securities?
Yes. Rule 6750 provides that every member firm that functions as a market maker in OTC Equity Securities by entering firm quotations into the OTC Bulletin Board Service (OTCBB) (or any other inter-dealer quotation system that permits quotation updates on a real-time basis) must honor those quotations for the minimum size as defined by the rule. In this regard, it is the market maker's responsibility to determine the minimum size requirement applicable to its firm bid and/or offer in each of its registered securities (excluding OTC Equity Securities for which the OTCBB will not accept firm quotations).

Because the Electronic Pink Sheets is an inter-dealer quotation system that permits quotation updates on a real-time basis, the minimum quote size requirements would apply equally to securities quoted on that system.

If the Electronic Pink Sheets displays three active priced quotations, is a broker/dealer required to call the market makers to verify their quotations appearing on the Electronic Pink Sheets?
NASD Notice to Members 92-50, Question #41 provides that if the OTC Bulletin Board displays three firm quotations in a particular security, than a member does not have to call the market makers to verify their quotations appearing on the OTC Bulletin Board pursuant to Article III, Section 1 and 21 (b) of the NASD Rules of Fair Practice (currently NASD Conduct Rules 2320 and 3110). A broker/dealer need only note on the order ticket the identity of the broker/dealers and the firm quotations obtained from the OTC Bulletin Board. Because the Electronic Pink Sheets will be an inter-dealer quotation system that permits quotation updates on a real-time basis, the same reasoning should be applied so that a broker/dealer need only note on the order ticket the identity of the broker/dealers and the firm quotations obtained from the Electronic Pink Sheets.

If a security is quoted on the Electronic Pink Sheets and the OTC Bulletin Board, will a broker/dealer have to check both quotation sources to achieve best execution for the firm's customers?
Yes. Best execution requires that a firm make use of all technology reasonably available to it and when reliable, take into consideration superior priced orders that are resident in electronic systems that reasonably and readily accessible. Since both systems would be readily available to most broker/dealers, a broker-dealer should review the quotations on both quotation systems before executing a customer transaction.

If the broker/dealer has checked all available quotable sources, obtained three or more competing priced quotes, will the broker/dealer be able to rely on the best bid/offer in executing retail transactions?
Not necessarily. Best execution is a facts and circumstances analysis which involves more than just checking markets to determine the best bid and/or offer. The factors to be considered include, but are not limited to, speed of execution, volatility, relative liquidity, pressure on available communications, the size and type of the transaction, the number of primary markets checked and the location and accessibility of primary markets and quotation sources. Based on the above, executing transactions at the "inside" quotation reflected on the Electronic Pink Sheets would not necessarily mean the broker-dealer met its best execution obligations, just as is the case with transactions in securities quoted in the OTCBB.


	QUESTIONS ABOUT WWW.OTCQUOTE.COM

Are the quotes on www.otcquote.com real-time?
Yes, but your browser is not automatically updated after you have received a quote. To get the latest quote, you must push the "refresh" button on your browser.

Who subscribes to www.otcquote.com?
Any individual or broker dealer interested in real-time Pink Sheets and Yellow Sheets quotations should subscribe.

Do I need to be a broker/dealer to access quotes?
No. OTCQuote.com enables you to view in real-time the inside quotes (price and size), market maker quotes (price and size) and market maker contact information and security lookup by name, symbol or CUSIP. However, you must be a broker/dealer to subscribe to the OTC Dealer and make markets.

What are the hours of operation for the Pink Quote system?
The service operates 11 hours a day, between 6 a.m. to 5 p.m. every business day. OTCQuote.com should be accessible 22 hours per day from 2 a.m. to 12 a.m., except when the service is down for maintenance and upgrades.

What types of stock/bonds are quoted on the www.otcquote.com?
Domestic and foreign stocks as well as corporate and trust bonds.

What does the "U" mean in the quote montage?
If there is a lowercase "u" next to the market maker symbol, it means the quote represents an "unsolicited" customer order. An uppercase "U" in the price column means an "unpriced" quote (market maker shows interest in trading but does not publish a price).

How do I sign up?
Please contact the Pink Sheets sales department by phone at (212) 896-4410, or by e-mail at sales@pinkotc.com

If I decide to cancel my subscription agreement, can I get my money back?
To cancel a subscription, please send customer service a letter requesting cancellation with a 30-day notice and you will be refunded for the months you haven't used if there is no open balance on your account.


	QUESTIONS ABOUT OTC DEALER

What does the OTC Dealer offer the subscriber?
The OTC Dealer gives users full access to tickers, quote montages and multiple watch lists for Pink Sheets and Yellow Sheets, a quotation service for all taxable debt. The OTC Dealer's true point-and-click functionality allows market makers to dynamically manage their quotes and to make markets. Market makers can submit one sided or two sided priced quotations, as well as un-priced or OW/BW indications of interest.

Is the OTC Dealer part of an order system?
No, the OTC Dealer is an informational quote system.

What prevents an unauthorized person from using the system?
Each user must have a secure User ID and Password in order to enter the system.

How long has the OTC Dealer been in existence?
The electronic OTC Dealer was launched September 15, 1999.

How does the OTC Dealer work?
The Dealer application is written in Java, a computer language that allows programs to operate independently of computer hardware or operating systems. Java Runtime Environment (JRE) that supports Java version 1.2 or Java 2 is required to run the Dealer application. The Dealer install application includes a Java Runtime Environment. Learn more about hardware requirements.

Can I connect to the OTC Dealer over a standard internet connection?
Yes.

Is the OTC Dealer real time?
Yes. The OTC Dealer allows broker/dealers to view real-time quote updates and dynamically manage their quotes.

What are the hours of operation for Pink and Yellow Sheet stocks?
The Dealer is open 11 hours per day. The service is available between 6am and 5pm every business day. However, individual traders at a market maker control when the trader's quotes are open and firm.

Do I need to be a broker/dealer to access the OTC dealer?
Yes, you must be a registered broker/dealer to access the OTC Dealer.

How do I register?
Please contact our sales and marketing department:
Phone: 212-896-4410
Email: sales@pinkotc.com

What does it cost to access the OTC Dealer?
The OTC Dealer Application costs $250.00 per month per Authorized User. There are discounts available for more than 5 users. View the Pricing Schedule.

If I decide to cancel my subscription agreement, can I get my money back?
Yes. You must fax customer service requesting a cancellation and you will receive a refund check for the months you haven't used provided there is no open balance on your account.

Do I have to connect to the OTC Dealer via the internet or is there another way?
IXnet is a network service provider which can provide a dedicated connection to the Pink Sheets. Connecting via the IXnet Liquidity Network requires a circuit charge. Please contact Mona Wachtel at (212) 412-6479 with any questions.

Can I subscribe if I live overseas?
You may only subscribe to the OTC Dealer if you are a United States SEC registered broker dealer. If not, you may subscribe to www.otcquote.com.

Why should I sign up for the OTC dealer?
You should subscribe if you are a broker/dealer that wants to manage his/her market quotes, as well as show un-priced or OW/BW indications of interest.

Can I use the OTC Dealer on a trial basis before I subscribe?
Yes, Please contact our sales and marketing department:
Phone: 212-896-4410
Email: sales@pinkotc.com


	CONTACT INFORMATION

If you have questions not covered in these sections, please contact us.

General Information and Investor Questions info@pinkotc.com

Issuer Questions
Issuer Services 212.896.4420 issuerservices@pinkotc.com

Subscription Information
Customer Service 212.896.4405, option 2 sales@pinkotc.com

Trial Subscriptions
Sales Marketing 212.896.4432 sales@pinkotc.com

Historical Pricing
Library 212.896.4483

Technical Information
Systems Department 212.896.4411

Glossary