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.
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