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March 4, 2026

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Last updated: March 4, 2026

Home  ›  Series 57  ›  When does a market maker need to file form 211 to quote an OTC Securit...

When does a market maker need to file form 211 to quote an OTC Securit...

Question: When does a market maker need to file form 211 to quote an OTC Security?

By: Securities Institute Staff
Instructor
SIA Instructor Verified SIA Instructor
2 hours ago

The first thing to keep in mind is that a market maker never has to file form 211 when requesting to quote a NASDAQ stock. An approved market maker who wishes to quote a NASDAQ stock will simply electronically request permission to quote the stock and will receive same day approval to enter their initial quote. If a firm wants to quote an inactive unlisted OTC stock, FINRA wants to know why. SEC Rule 15C2-11 (as amended) sets the standards for non listed companies to develop a public market and for broker dealers to publish quotations for the securities. SEC 15c2-11 requires issues to be current when reporting and disclosing financial and other information. The OTC Markets Group acts as a qualified interdealer quotation service (IDQS) and monitors issuers compliance on an ongoing basis to ensure that issuers are current with their disclosures. A broker dealer wishing to quote an OTC security will be able to rely on the current information designation made by the IDQS in lieu of submitting Form 211 with FINRA. In order for an issuer to maintain its designation as being current, SEC reporting issuers must continuously make timely filings of all reports. Companies listed on the OTCQX, OTCQB and PINK Current are subject to this rule. If companies fail to meet this continuing reporting requirement, the security will be deemed ineligible for public quotes. During market hours quotes for these ineligible securities will be shown as zero (0). However, last sale data for the stock will be available at the end of the day. If the security is deemed to be inactive The issue must work with the broker dealer to file form 211 with FINRA. Rule 15c2-11 permits additional time (180 days) for Exchange Act reporting companies to continue to be eligible for public broker-dealer quotes. Accordingly, companies that make their annual or quarterly reports publicly available (via EDGAR) within 180 days of the end of the reporting period will still be eligible for broker-dealer proprietary quotes, but will be designated as “Limited Information”. Companies who have no information available may be traded on either the OTC Expert market or be forced into the Gray market. The OTC Expert market is where broker dealers may publish unsolicited quotes based on customer limit orders to obtain the best possible execution for the customer. Quotes in the Expert Market are restricted from public view. The Gray market is not an electronic market. The stock of issuers whose securities have been delisted or who are no information companies will be traded over the phone between broker dealers. The Gray market lacks the price discovery made available in electronic markets. Investors should be extremely cautious when considering purchasing securities in either the Expert or Gray market.

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