Trading Services FAQs

How do I begin quoting/trading off-exchange securities?
What regulations do I need to be aware when quoting/trading off-ecxhange securities?
What is Rule 15c2-11?
What is the Piggy-Back rule?
Do I still have to report trades to FINRA?
Do I have to file a Form 211 for a security that has been delisted from the New York Stock Exchange, NASDAQ or NYSE-AMEX?
Are the priced quotes in the OTC Link system considered firm by FINRA rules?
What would constitute "backing away" within the OTC Link system?
Are there minimum quote sizes in the OTC market?
Are there quote price increments for OTC securities?
Is there a way quote a security without a Form 211?
Is there a 15c2-11 exemption for unsolicited quotes?
What are OTC Markets Group's guidelines regarding the publication of unsolicited quotes?

OTC Data Center Migration Project FAQ

General Questions

What is the OTC Data Center Migration Project?
How is my firm affected?
What are the key dates for this change?
Who do I contact if I have additional questions?

FIX Related Questions

How is my FIX Service impacted?
How do we test against the new FIX IP, ahead of cutover?
What do we need to do on the day of cutover?
We have multiple FIX connections. Do we need to cut them all over on the same day?
How can we roll back if any issues are encountered?
For how long will our old FIX IP still be available after we cut over?

Dealer Related Questions

How is Dealer Service impacted?
How can we test against the new server IP, ahead of cutover?
What do we need to do on the day of cutover?
How can we roll back if any issues are encountered?
When will the old server IP be decommissioned?

Multicast Feed Related Questions

How are the Multicast Feeds impacted?
How do we test against the new feeds, ahead of cutover? Are the old and new feeds completely identical?
What do we need to do on the day of cutover?
We subscribe to multiple feeds. Do we need to cut them all over on the same day?
How can we roll back if any issues are encountered?
When will the old feeds be decommissioned?

How do I begin quoting/trading OTC securities?     Top
Only FINRA registered broker-dealers may quote and trade OTC securities. “Market Making” firms may quote and trade while “Order Entry” firms may only trade. FINRA determines the broker-dealer’s status. Once FINRA has assigned your firm a Market Participant Identifier (MPID), you may contact OTC Markets Group's Trading Services department at tradingservices@otcmarkets.com or 800.LIST.OTC to begin the enrollment process.

What regulations do I need to be aware when quoting/trading OTC securities?     Top
The best source for all of the applicable rules governing the OTC market may be found in the FINRA Manual. OTC Markets provides a synopsis of the FINRA Rules in the “OTC Market Regulation” document, including the rules surrounding Firm Quotes (FINRA Rule 5220), Minimum Quote Sizes (FINRA 6433), Best Execution (FINRA Rule 2320), and others.

What is Rule 15c2-11?      Top
Rule 15c2-11 under the Securities and Exchange Act of 1934 (Exchange Act) governs the submission and publication of quotations by brokers and dealers for OTC equity securities. Specifically, the rule applies to a broker-dealer's initiation or resumption of quotations for such securities in any inter-dealer quotation system, including OTC Link. 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 SEC Rule 15c2-11. Get a copy of the Form 211.

What is the Piggy-Back rule?      Top
The Piggy-Back rule stipulates that a security is eligible for quoting under Rule 15c2-11 without the submission of a Form 211. Any authorized market maker may begin quoting piggy-back eligible securities at any point in time. The "piggy-back" exception is based on a market maker publishing quotations for a security in an applicable interdealer quotation system (OTC Link or the OTCBB) on at least 12 business days during the preceding 30 calendar days, with not more than four consecutive business days without quotations.

Do I still have to report trades to FINRA?      Top
Yes – you are responsible for reporting trades to FINRA through ORFTM. OTC Markets offers a number of services that automate the reporting process. You may receive FIX drop copies messages to integrate into your internal systems or drop copies may be sent to a third party Order Management System (OMS) such as BRASS. OTC Markets can also submit executions directly to FINRA’s ORF, formerly known as ACT, on your behalf.

Do I have to file a Form 211 for a security that has been delisted from the New York Stock Exchange, NASDAQ or NYSE-AMEX?      Top
Yes – listing on NYSE, NASDAQ or NYSE-AMEX does not exempt a Market Maker from filing a Form 211. If, however, the security was quoted on OTC Link prior to the delisting it may be considered "piggyback" eligible.

Are the priced quotes in the OTC Link system considered firm by FINRA rules?     Top
FINRA Rule 5220 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. For purposes of compliance with FINRA Rule 5220, unless designated as a non-firm quotation by the broker-dealer or by the rules of the inter-dealer 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. See complete FINRA Rule 5220.

What would constitute "backing away" within the OTC Link system?      Top
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.

Are there minimum quote sizes in the OTC market?      Top
Yes – FINRA Rule 6433 defines the minimum quote sizes for different price levels. See complete Rule 6433.

Are there quote price increments for OTC securities?     Top
OTC Markets sets price increments for OTC Link-only securities – securities that are quoted only on our OTC Link system. The below rules do not apply to securities quoted on both OTC Link and the OTCBB or only on the OTCBB.

Quote increment rules:

  • For quote prices above $1, a quote tick size of 0.01
  • For quote prices under $1, a quote tick size of 0.0001

For securities priced below $1, quote “rounding” rules will be eliminated as the quote increment is now the smallest interval allowed in OTC Dealer and through OTC FIX. Quote rounding will continue to be applied for securities priced above $1.

Is there a way quote a security without a Form 211?      Top
Yes, if a broker-dealer determines the security is eligible for one of the following exceptions under SEC Rule 15c2-11:

  • The security is currently listed on a U.S. exchange.
  • The broker-dealer wishes to submit an unsolicited quote. An unsolicited quote represents a customer order and not a broker-dealer’s own position and must be removed from the system once the customer order is executed. See the unsolicited quote FAQs.
  • The security is piggyback eligible. A security becomes piggyback eligible when it has been quoted on the OTC Link system by at least one market maker for a minimum of 30 days.
  • The Globenet Exemption. Under this exemption, a market maker can initiate a quotation on the OTC Link system for an OTCBB-only quoted security without submitting a Form 211 to FINRA, subject to the following conditions:
    1. Each broker or dealer relying upon this exemption must have in its records information specified in paragraphs (a)(5)(i), (a)(5)(viii), (a)(5)(xiv), (a)(5)(xv), and (a)(5)(xvi) of Rule 15c2-11;
    2. Two-way bid and ask priced quotations that do not reflect customer indications of interest must have been published during the previous 30 calendar days, with no more than four business days in succession without such quotations, in an interdealer quotation system that displays unsolicited customer indications of interest;
    3. The issuer of the security has not been delinquent in any of its reporting obligations under the Exchange Act or rules thereunder for more than 30 days, if subject to Section 10(a) or 15(d) of the Exchange Act;
    4. Since the issuer of the security filed its most recent annual report, the issuer has not filed a report with respect to any event included in Item 1.03 (Bankruptcy or Receivership), Item 2.01 (Acquisition or Disposition of Assets), Item 4.01 (Changes in Registrant's Certifying Accountant), Item 5.01 (Changes in Control of Registrant), and Item 5.02 (Departure of Directors or Certain Officers) of Form 8-K under the Exchange Act; [Updated in 2004 per Modification of 15c2-11 Exemptive Letters]
    5. The issuer of the security is not exempt from the registration requirements under Section 12(g) of the Exchange Act pursuant to Rule 12g3-2(b); and
    6. The issuer of the security is not the subject of bankruptcy proceedings.

Is there a 15c2-11 exemption for unsolicited quotes?      Top
Yes - SEC Rule 15c2-11 provides an exemption to filing a Form 211 with FINRA for broker-dealers that wish to publish an unsolicited quote. An unsolicited quote represents a customer order and not a market maker's own position and must be removed from the system once the customer order is executed. Compliance with this rule is monitored by FINRA.

What are OTC Markets guidelines regarding the publication of unsolicited quotes?      Top
OTC Markets has become increasingly concerned that the unsolicited quote exception in SEC Rule 15c2-11 is being abused by unscrupulous individuals to engage in questionable and possibly fraudulent activities in violation of the federal securities laws. OTC Markets, as a matter of policy, does not believe that the Unsolicited Quote Exemption should be used to circumvent FINRA's 211 process. As a result, effective February 6, 2006, OTC Markets is limiting the publication of unsolicited quotes to securities of seasoned issuers only. A seasoned security is generally defined as a security for which there has previously been a public market or a security of an issuer that has other seasoned securities.

OTC Markets generally will publish unsolicited quotations in securities that meet one of the following five conditions:

  1. The Issuer of the securities is subject to Section 13 or 15(d) of the Exchange Act, is current in its filing obligations and has other seasoned securities currently trading on the NYSE, AMEX, NASDAQ, or quoted on OTCBB or OTC Link.
  2. The securities were recently delisted from NYSE, AMEX, NASDAQ or deleted from the OTCBB;
  3. The Issuer is a bank, savings and loan, or insurance company;
  4. The securities were issued as part of a bankruptcy plan of reorganization; or
  5. The security being quoted is a foreign ordinary, which is listed on a foreign exchange, or an ADR representing such ordinaries

In order to publish an unsolicited quote for a security that meets one of the above conditions and is not already quoted on the OTC Link system, a broker should submit the Broker/Dealer Unsolicited Quote Entry form to OTC Markets Group.

Issuers of previously unseasoned securities that had quotations published on OTC Link prior to February 6, 2006 using the unsolicited quote exemption and continue to be quoted only on an unsolicited basis are required by OTC Markets to continue to make periodic disclosure using the OTC Disclosure and News Service. If the Issuer ceases to provide current information, OTC Markets may cease to allow broker/dealers to publish quotes in its securities.

OTC Data Center Migration Project FAQ

General Questions

What is the OTC Data Center Migration Project?     Top
OTC Markets is transitioning our existing primary data center in Carlstadt NJ, to a modernized location in the same facility. This change will give us more flexibility and scalability, thus allowing us to provide better services to you.

How is my firm affected?     Top
If you are using any of OTC Markets’ externally facing services – FIX, Dealer, or Multicast feeds, you will need to update your application configurations to connect to our new services, which are available at new IP addresses. Please see sections below for specific cutover information on each of these three services.

What are the key dates for this change?     Top
We will be making our services available in our new data center from May 6th, 2013. The old data center is slated to be decommissioned on June 16, 2013. Thus a 6-week time window is available for testing and implementing the cutover. The actual service cutover dates will be driven from the client side, on a per-client, per-service basis. i.e. there is no big-bang synchronized cutover date. If you subscribe to multiple services, these can be cutover on different dates of your choice, independent of each other.

Who do I contact if I have additional questions?     Top
You can email us at datacentermigration@otcmarkets.com, or call our help desk at 212.896.4411

FIX Related Questions

How is my FIX Service impacted?     Top
We have put up a new set of FIX engine instances in our new data center. The new FIX target IP address is 199.124.25.44. The new instances are identical in all other respects to the existing FIX engines in our current data center. You will need to:

  1. Work with your network team to update routing and firewall rules to allow your FIX engine(s) to connect to our FIX engines IP. Provide your network team with the new target TCP IP and your current TCP ports. Note that while the IP is the same for all clients and connections, the TCP ports are per-connection and will remain the same as in our old Data Center. e.g. if you are currently connecting to IP a.b.c.d Port 7604, you would now need to connect to IP 199.124.25.44 Port 7604.
  2. Test network connectivity by doing a Telnet test to the FIX IP and port from your FIX engine.
  3. Schedule a cutover date with OTC Markets tech support. On the evening before cutover, update your FIX engine connection configurations to target our new FIX engines. Working with OTC Markets tech support, do a FIX heartbeat test (and optional business messaging test).
  4. If test is deemed successful, reset sequence numbers and keep the new config info in place, and let your FIX engine connect to our new FIX engine the next morning.

How do we test against the new FIX IP, ahead of cutover?     Top
We recommend you test connectivity in two steps (and optionally three):

Step 1 - Testing Network Connectivity: Ensure that you can telnet from your FIX engine server(s) to the new IP (the port remains unchanged). The test can be done at any time during the day, and you do not need to pre-schedule the test with us.

Step 2 - Testing FIX Heartbeats: Call OTC Markets tech support team to schedule this test. The test should typically be done the evening before your production cutover. The test will ensure that FIX engines on both sides are correctly configured to allow your engine to log into our engine and exchange heartbeats. Note that the new engine will be expecting sequence numbers at 0/0, so you will need to reset sequence numbers on your end before connecting the FIX session. The testing will typically be scheduled for weeknights after 5:15pm, though weekend testing is also an option.

Optional Step 3 - Testing Business Messaging: Since the new FIX engine on the new IP is identical to the existing engine from a software viewpoint and pre-tested by us, testing business messaging functionality is not required. However, if you wish to run such a test we will schedule it along with the above heartbeat test. Please note that the new FIX engine will be connected to our Production network, so testing must be limited to Test symbols (TESTJ, TESTF, TESTY). For testing quote connections, you can send a Quote Update message and watch for a Quote Ack message back, or watch for the quote to be received on our Production multicast quote feed. For testing Trade or DropCopy connections, we will log in as a test counterparty so you can execute a trade with us on a test symbol.

What do we need to do on the day of cutover?     Top
On the evening before the cutover date, you will need to modify your FIX engine connection configuration and replace our existing IP with the new target IP. On OTC Markets side, we will enable your connection in our new Data Center, and disable your old connection in the old Data Center. Then you would need to go through the testing step 2 (and optionally step 3) described above in the Test section. At the end of testing, leave the new configs in place and reset sequence numbers. The next day your FIX engine will then initiate its connection against this new IP.

We have multiple FIX connections. Do we need to cut them all over on the same day?     Top
No. There are no dependencies between any FIX connections (quote, trade, drop copy1, dropcopy2, etc). You can choose to cut them all over on the same day, or over multiple days. There are also no dependencies between FIX cutovers and Dealer or Multicast feed cutovers, if you subscribe to those services.

How can we roll back if any issues are encountered?     Top
If a rollback is deemed necessary, you will need to undo the change to your FIX engine connection configuration and reset sequence numbers to 0/0. Depending on how your FIX engine is set up, it may need a restart for the updated connection configuration to take effect. You will also let us know so we can re-enable your FIX connection to the old engine (and disable your connection on the new engine). Once the configuration changes on both sides have taken effect, you will be able to connect to our old FIX engine.

For how long will our old FIX IP still be available after we cut over?     Top
The fix connection in our old data center will be disabled on the day we cutover your connection to the new data center. However, we will keep the connection configured in case a rollback is needed for any reason. All connections to our old data center will be deleted on the decommissioning date. See answer above to question "What are the key dates for this change?".

Dealer Related Questions

How is Dealer Service impacted?     Top
We have set up a new set of Dealer services on new servers with new IP addresses in our new data center.


The new services are identical in all respects to the existing services in our current data center. You will need to:

  1. Work with your network team to update routing and firewall rules to allow your Dealer desktops to connect to our new server IPs. Provide your network team with the target IP table above. Note that if you connect to OTC Markets via an Extranet or a Direct link, they need to configure the first (non-internet) set of IP addresses. If you connect via the Internet, the second set needs to be used. Your network team will know how you connect. Also note that for our Cert environment, the same set of target IPs are used for both Internet and non-Internet connections.
  2. Test network connectivity by doing a Telnet test from each Dealer machine to all three of the new TCP IPs and Ports (under either Internet or non-Internet, depending on your connectivity).
  3. Pick a cutover date or series of dates. You will probably want to cutover a single user first, and then cutover remaining users on a subsequent day or days.
  4. On evening before cutover date, replace the existing Dealer config file (listhost.properties) with the new one linked here [todo - link to file]. This file is situated in the (version specific) Dealer installation directory. For example, on Windows 7 64-Bit installations of Dealer 5.5.3.1, the file will typically be at C:/Program Files/OTCDealer5.5.3.1.

How can we test against the new server IP, ahead of cutover?     Top
We recommend you test connectivity in two steps.

Step 1 - Testing Network Connectivity: Ensure that you can telnet from your Dealer desktops to the new IPs and ports. The test can be done at any time during the day, and you do not need to pre-schedule the test with us.

Step 2 - Testing Dealer Login: Replace the existing listhost.properties file (keep a backup) with the new one provided. Start up Dealer and login with user credentials. If you can log in successfully you are good to go. You can leave the new listhost.properties in place, and the user will henceforth connect to the new Data Center. This test can be done at any time, but we recommend waiting till market close.

What do we need to do on the day of cutover?     Top
To cutover a Dealer user, simply test Dealer login the previous evening (see testing section above), and then leave the new listhost properties file in place. You do not need to schedule the cutover in advance with us, and you do not need to contact us on day of cutover either, unless of course you need help.

How can we roll back if any issues are encountered?     Top
To roll back a Dealer cutover, you would need to revert to the old list host.properties file and restart Dealer. You would need to do this for each Dealer install you want to rollback. Again, you do not have any dependency on our side for this change, though you will probably be in touch if your users are facing issues.

When will the old server IP be decommissioned?     Top
The old services will be deleted on the data center decommissioning date. See answer above to "What are the key dates for this change?".

Multicast Feed Related Questions

How are the Multicast Feeds impacted?     Top
We currently publish two sets of multicast feeds - a set of A feeds out of our primary data center and a set of B feeds out of our secondary data center. The A feeds are being replaced with a set of A' feeds out of our new primary data center. The A' feeds are published on a new set of IP multicast groups and ports. And the corresponding TCP retransmission channels are moving to new IP/Port addresses. Other than this IP change, the A and A' feeds are identical at the message level.


You will need to:

  1. Work with your network team to update routing and firewall rules to allow the new multicast groups to reach your servers, and to allow retransmission requests to reach our new servers. Provide your network team with the new TCP and UDP IPs and ports and the IP of your feed handler server.
  2. Test TCP network connectivity by doing a Telnet test from your feed handler our new retransmission channels. There is one retransmission channel for Binary feeds and a second retransmission channel for secondary feeds. Test UDP network connectivity by sniffing for multicast traffic on the set of multicast groups you subscribe to (quote book feed, level 1 feed, etc).
  3. Set up a parallel test feed handler instance to listen to the new A' feeds and reconcile received data against the Production A feeds. This is a recommended but not required step.
  4. Pick a cutover date. On evening before cutover date, make your A' feed handler the Production one, and put your A feed handler in backup mode (for a day or two) before retiring it. Or if you have chosen not to implement step 3 above, simply update the configuration of your Production feed handler to switch to the new A' multicast groups and retransmission channels. You do not need to contact us to schedule a cutover date, but we would like to get a notification for our own tracking purposes.

How do we test against the new feeds, ahead of cutover? Are the old and new feeds completely identical?     Top
Our multicast feeds consist of a series of multicast packets, each containing one or more messages. The A and A' feeds are identical at the message level, though not at the packet level. This is similar to the difference between our A and B feeds. You can set up a test A' feed handler instance that listens to the new feeds, and inserts the data into a test database or flat files. You can then run a job to compare this data against the data received by the A feeds. Or you can create a custom feed handler that listens to both A and A' feeds and reconciles them on the fly. If you have a current methodology to reconcile our A and B feeds, you can reuse that to reconcile our A and A' feeds.

What do we need to do on the day of cutover?     Top
Once you are confident that you are receiving our new feeds without any significant drops, you can cutover by making your test A' feed handler the Production handler, and your old A feed handler the backup one. If you have chosen not set up a parallel A' feed handler in advance, you would just reconfigure your Production A feed handler to listen to the new A' multicast addresses (and use the A' retransmission channel).

We subscribe to multiple feeds. Do we need to cut them all over on the same day?     Top
No. You can choose to cut them over one at a time, across multiple days. Just remember that retransmission requests for an A' feed need to be sent to the A' retransmission channel, and those for an A feed need to continue to be sent to the A retransmission channel.

How can we roll back if any issues are encountered?     Top
If issues are encountered with the new A' feeds, please contact us to troubleshoot first. If it is determined that you need to rollback, you will need to switch from your new A' feed handler instance to the old A feed handler instance. Or if you are using a single feed handler instance, reconfigure it to listen to the old A multicast groups (and use the old TCP retransmission channels). On reconnecting to the A feeds, you can issue a snapshot request to sync up.

When will the old feeds be decommissioned?     Top
The old data center A feeds is slated to stop publishing on June 16, 2013. See detail in the above question “What are the key dates for this change?.”

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