Public Policy Advocacy

Comment Letters & Government Testimony by OTC Markets Group on issues impacting our markets

Capital Formation

FINRA Rule 6432 Comment Letter, January 8, 2018
Comments submitted to FINRA related to FINRA Rule 6432 and the Form 211 process. Our comments advocate for a disclosure-based approach to the administration of Rule 6432 and offer a number of proposals to address existing issues and modernize the Form 211 process.

OTC Markets Group Testimony on Reducing Barriers to Capital Formation, June 12, 2013
Testimony of R. Cromwell Coulson, President and CEO of OTC Markets Group Inc. Before the Subcommittee on Capital Markets and Government Sponsored Enterprises Committee on Financial Services Hearing Entitled "Reducing Barriers to Capital Formation.


13(f) Comment Letter, April 30, 2013
Comments submitted to the SEC on the petition for rulemaking under Section 13(f). Our comments focus on expanding the scope of 13(f) reporting to include all non-SEC reporting OTC equity securities traded on the OTCQX, OTCQB, and Pink markets.

Regulation A+

Petition for Rulemaking to Amend Regulation A to make SEC Reporting Companies Eligible Issuers and Permit At the Market Offerings, June 6, 2016
Petition to the SEC urging them to expand Regulation A+ to allow SEC Reporting Companies to utilize this important form of online capital raising.

Proposed Amendments to Regulation A, March 24, 2014
Comments submitted to the SEC in support of the Proposed Rules, including the expansion of maximum offering size, bad actor disqualification, and Blue Sky preemption of offerings done under Tier 2 of Regulation A. See all comments: Comments on Proposed Rule Amendments for Small and Additional Issues Exemptions Under Section 3(b) of the Securities Act

JOBS Act Comment Letter – July 9, 2012
Comments submitted to the SEC related to Section 201 of the Jumpstart our Business Startups (“JOBS”) Act. These comments focus on rulemaking related to general solicitation and advertising, focusing on the valuable role of publicly available price information in securities for which general solicitation and advertising is permitted.

Venture Markets

Main Street Growth Act (H.R. 4638), March 1, 2016
Letter submitted to Chairman Hensarling, Ranking Member Waters, Chairman Garrett and Ranking Member Maloney regarding markups to the Main Street Growth Act that affect Venture Markets.

BX Venture Comment Letter - January 24, 2011
Letter describing flaws in the proposed operating procedures of the planned BX Venture Market. Many of the points raised in this letter were included in the final rule approving the BX Venture Market.

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