What are the OTC Market Tiers?

Pink OTC Markets assigns an OTC Market Tier to each OTC traded company based upon the disclosure it provides to the market-place.

Pink Sheets companies are identified as providing current information, limited information or no information by one of the following icons:

Companies may provide disclosure to the marketplace through a selected US regulatory agency (i.e. SEC), a qualified foreign stock exchange or directly through the OTC Disclosure and News Service, offered by Pink OTC Markets.

How can a Company Provide Disclosure to the Marketplace?

Pink OTC Markets has created Guidelines for Providing Adequate Current Information to help companies understand what information is material and should be disclosed.

Pink Sheets companies can decide which OTC Market Tier they wish to be in and tailor their disclosure accordingly.

To upgrade from No Information to Limited Information:

• Subscribe to the OTC Disclosure and News Service.
• Post a disclosure document pursuant to the Guidelines for Providing Adequate Current Information for a period ending within the last six months. At a minimum, this must include a balance sheet, income statement, and total shares outstanding. Financial statements must be prepared in accordance with US GAAP, but are not required to be audited.
• Pink OTC Markets will automatically be alerted to the posted disclosure and move the OTC Market Tier to Limited Information or contact the issuer for further information.

To upgrade from No Information or Limited Information to Current Information:

• Subscribe to the OTC Disclosure and News Service.
• Post an Initial Company Information and Disclosure Statement, pursuant to Section One of the Guidelines for Providing Adequate Current Information (PDF) through the OTC Disclosure and News Service. Complete financial statements from the most recent quarter end as well as from the prior two years must be included. Financial statements must be prepared in accordance with US GAAP, but are not required to be audited.
• Submit a signed Attorney Letter Agreement (first two pages of Pink OTC Markets Guidelines for Attorney Letters with Respect to Adequate Current Information).
• Post an Attorney Letter complying with Pink OTC Markets Guidelines for Attorney Letters with Respect to Adequate Current Information through the OTC Disclosure and News Service.

Pink OTC Markets will automatically be alerted to the posted Attorney Letter and within 3 to 5 business days:

• Confirm that a signed and dated Attorney Letter Agreement has been submitted
• Verify that company has met the requirements for Current Information
• Move the OTC Market Tier to Current Information or contact the issuer for further information.

To remain in Current Information:

• Post subsequent Quarterly Reports pursuant to Section Two and Annual Reports pursuant to Section One of the Guidelines for Providing Adequate Current Information (PDF).
• Post an Attorney Letter for each period end.

Pink OTC Markets will automatically be alerted to the posted documents and will:

• Verify that the company has posted the required Quarterly Reports within 45 days following each quarter end and Annual Reports within 90 days following each fiscal year end. Companies will be downgraded to Limited Information if reports are not posted in this timeframe.
• Confirm that an Attorney Letter is posted for the period end. Companies are given an additional 30 days beyond the disclosure statement due date to post the Attorney Letter.

Financial Report Timeline for Maintaining Current Information - FY 12/31 Filers
Fiscal Period End Date	Report Type - Due Date
12/31/2009	Annual Report - 3/31/2010 Attorney Letter - 4/30/2010
03/31/2010	Quarterly Report - 5/15/2010 Attorney Letter - 6/14/2010
06/30/2010	Quarterly Report - 8/14/2010 Attorney Letter - 09/13/2010
09/30/2010	Quarterly Report - 11/14/2010 Attorney Letter - 12/14/2010
12/31/2010	Annual Report - 3/31/2011 Attorney Letter - 4/30/2011

*Companies following the Alternative Reporting Standard to maintain Current Information can file a Notification of Late Filing for an extension of 5 calendar days to file a Quarterly Report and 15 calendar days to file an Annual Report.

What is the Advantage of Providing Disclosure to the Market?

Companies that undergo stock promotions or certain corporate actions, such as a reverse merger or name change without adequate current information available, will be labeled with Caveat Emptor until such a time as they do provide current information to the market.

[For more information, visit Requirements for OTC Market Tiers.]