OTC Trading and Expert Market

This page is for discussion on OTC market trading as well as discussion relative to rule 15c2-11. Rule 15c2-11 is from 1971 and says that security issuers must have ‘current information’ on file, but allows the issue to continue to trade even when NO current information is on file.

Here is an article which covers rule 15c2-11 which was posted originally by 8675309xyz in the Sandbox on 8/27/2021.

Here is another more official resource as posted by Justin on 9/27/2021.

This item was posted by AzureBlue on 8/15/2022

OTC Blog discussion on expert markets.

328 thoughts on “OTC Trading and Expert Market”

  1. I know there is a “show or fill” rule with the SEC but I must not be triggering the lower of the “ask”. It is a price improvement, idk. Maybe because of some OTC rules. I am still learning but this is the order I have out there that is not filling but is better than if someone just bought at 32.95. I wonder if the buy would fill at my ask or the higher shown rate?

    asking 32.00 (TD shows 32.95)
    yield: (.4875 X 4) / 32.00 = 6.094 %

    1. Chevron doctrine is [d]ead. First one to take SEC to court in it’s unfair practice clearly [o]verreach of authority and the so called “expert market ” is dead

      Brokers are over reading the rule and if retail is limited to sell only an unfair advantage is given to the buy side

      Just my 2cents on the aplication of rule 15c2-11 as it relates to all otc equity

      Lastly and funny
      cryptocurrencies can trade huh?

    2. OTC orders are not shopped to all brokers you often have the best price but don’t get the fill. The big sharks have priority either because of kickbacks or because of simplicity.
      SEC represents the big fish a lot more than they care about the little guys like us that’s just talking points to justify their jobs.

  2. Which brokers allow purchasing securities from the Expert Market? As far as, I understand almost no one offers these even if you’re an accredited investor.

    1. Fidelity offers some of them but not others. More than any other account I have but no Bid?ask numbers you need to guess. I’ve heard IBR offers some but I don’t have an account there. Or even the robinhood types if you want to go down that rabbit hole.

  3. The SEC announced an exemption from Rule 15c2-11 for Rule 144A securities earlier today:

    Order Granting Broker-Dealers Exemptive Relief, Pursuant to Section 36(a) and Rule 15c2-11(g) under the Securities Exchange Act of 1934, from Rule 15c2-11 for Fixed-Income Securities Sold in Compliance with the Safe Harbor of Rule 144A under the Securities Act of 1933

    “The Commission finds it is appropriate in the public interest, and consistent with the protection of investors, to exempt brokers and dealers from the requirements of Rule 15c2-11, with respect to Rule 144A fixed-income securities.”

    There’s no joy for “equity” style fixed income securities, however – have a look at footnote 15:

    /15 The Petition was limited to Rule 144A fixed-income securities and expressly excluded equity securities sold in compliance with the safe harbor in Rule 144A. See Petition at n.1. Moreover, the amendments to Rule 15c2-11 have applied to Rule 144A equity securities since the compliance date of those amendments which was September 2021. Accordingly, this exemption does not address equity securities sold in compliance with the safe harbor in Rule 144A.

    1. I’m very dumb. I wonder if someone could spell out in English what this means? Does anything change with the expert market.

  4. Finally, here’s a reputable academic survey of the unexpected application of 15c2-11 to fixed income securities. The article’s focus is on the impending application of the rule to Rule 144A securities, but it traces how poorly the rule was understood at the time of enactment and proposes a solution. Very interesting reading for income investors who have been affected by the rule!
    Yale Journal on Regulation

    Fixed Income Securities and SEC Rule 15c2-11: History, Context, Uncertainties—and a Pathway Forward

    * Jeffrey T. Dinwoodie†September 25, 2023

    This Article discusses a topical legal issue in the areas of securities, corporate, and administrative law: an ongoing controversy regarding the SEC’s broker-dealer quoting rule, Rule 15c2-11 under the Securities Exchange Act of 1934. For the past fifty years, the rule has been understood to apply only to equity securities (primarily, penny stocks). But more recently, the SEC staff has stated that the rule also actually applies to fixed income securities, such as corporate bonds and asset-backed securities. This SEC staff interpretation has set off a wave of uncertainty across the financial services industry about the application of a rule to fixed income securities that many believe was actually designed for equity securities. After tracing the regulatory history of the rule, its purpose and these recent developments, the article ultimately recommends a pathway forward for the SEC to address this regulatory conundrum—a pathway that would stem the market uncertainty and also advance the SEC’s investor protection mission.

    Proposed solution:
    Rather than ignoring the uncertainty and, as two SEC Commissioners82 put it, potentially “trying to shoehorn [fixed income securities] into a rule designed for equity securities,” the SEC could take the following two steps, which would stem the uncertainty and ultimately advance the agency’s mission: (1) extend the November 2022 no-action relief indefinitely, so as to preserve the status quo; and concurrently (2) release a request for public comment to facilitate a formal evaluation and development of a public report or release discussing what, if any, additional safeguards or restrictions governing fixed income quoting activities may be necessary—and if so, how they should be structured and tailored for different types of securities. Based on the results of that evaluation, the no-action relief could then be amended or terminated, as appropriate, in conjunction with any other appropriate regulatory action.


  5. Lawsuit filed in federal court seeks to avoid SEC rule 15c2-11’s application to fixed income / Rule 144A securities:
    Manufacturing organizations sue SEC over rule reinterpretation

    The National Association of Manufacturers and the Kentucky Association of Manufacturers sued the SEC Sept. 12 over its reinterpretation of a rule that would require increased disclosure from private companies.
    In 2020, the SEC adopted amendments to the rule — known as Rule 15c2-11 and originally adopted in 1971 — preventing broker-dealers from publishing quotations for an issuer’s security in the over-the-counter market unless current issuer information is publicly available.
    In September 2021, the SEC issued a new interpretation of the rule, applying its disclosure requirements “on private companies that raise capital via corporate bond issuances under SEC Rule 144A — without giving manufacturers the opportunity to provide comment on the damaging impacts of such a consequential change,” according to a Sept. 12 news release from the National Association of Manufacturers, or NAM.
    NAM and the Kentucky Association of Manufacturers, which jointly filed a lawsuit in the U.S. District Court for the Eastern District of Kentucky, said that forcing private companies to disclose confidential financial information to the public is a violation of the Administrative Procedure Act, which governs how federal agencies develop and issue regulations.
    “The SEC never allowed public comment on its novel reinterpretation of Rule 15c2-11, there is no conceivable benefit to the new standard, and the SEC did not consider the impact that its about-face will have on privately held businesses — which could exceed 100,000 lost jobs each year,” NAM chief legal officer Linda Kelly said in the news release. “The NAM Legal Center is filing suit to hold the SEC accountable and protect manufacturing growth, job creation and U.S. competitiveness.”
    In November, the plaintiffs filed petitions for rulemaking with the SEC, seeking permanent and temporary relief from the reinterpretation of the rule. Following that move, the SEC temporarily delayed enforcement of its reinterpretation until January 2025 but has not taken action to reverse the reinterpretation, according to the NAM news release.
    When asked for comment, an SEC spokesperson said, “We are reviewing these filings and will respond appropriately.”


    Link to complaint:


    Macroeconomic impacts of applying Rule 15c2-11 to Rule 144A debt issued by private US companies
    Prepared for the National Association of Manufacturers (NAM)
    September 2023


  6. One of the preferred I have a position in has moved onto the ‘expert market’ After being listed I was able to buy / sell it still for a while, but I noticed it went down substantially and tried to make a buy order and it failed. I checked with ML, JPM and IBKR all 3 wont trade it.

    Any idea on how to buy a preferred that is now on the expert market?

  7. Does anyone here know how to determine the unique number of individual stockholders for any given series of preferred shares? As far as I can tell, this information isn’t made publicly available.

    As many of you have noticed, there have been a recent raft of take-private proposals that could potentially affect the preferred shares of the company that is taken private. I am trying to figure out a way to avoid getting “GMLPF’d” – that is, having the preferred shares removed by an Exchange due to an inadequate number of preferred shareholders (that’s what happened with GMLPF, which was delisted from the NASDAQ Global Market due to an inadequate # of stockholders). With the delisting comes, of course, illiquidity, due to the unfortunate and unforeseen aspects of SEC Rule 15c2-11.

    I am thinking here of SiriusPoint, Triton International, and the GasLog Ltd. / GasLog Partners preferred shares. If, say, Dan Loeb successfully consummates his take-private of SiriusPoint, could the SPNT-B shares be delisted by the NYSE (of its own volition, following its own rules) due to an inadequate number of SPNT-B stockholders?

    I have called and emailed the “NYSE Listed Companies” contacts (https://www.nyse.com/contact) but not heard back.

    Thank you!

    1. Keep in mind “going dark” “delisted” and “expert market” are not the same thing. I own “delisted” issues that are neither “dark” nor expert market. I also own a “dark” preferred that is delisted but not on expert market. So the terms are not synonymous.
      Just as a stand alone comment all shareholders holding in street name are generally viewed as one shareholder per brokerage.
      This explains it a little bit in terms of a company wanting to go dark…
      Both U.S. domestic issuers and foreign private issuers can delist and/or deregister if there are less than 300 holders of record of the relevant class of its securities as defined in Rule 12g5‑1. It is possible for a company to have less than 300 holders of record of a class of securities even though it has thousands of beneficial owners of that class of securities. This is because, in counting record holders, in general, the issuer need only count the number of registered holders on its shareholder list and if depositaries are listed, the number of holders for whom the depositary holds securities. For most U.S. issuers, this mean counting the registered holders and adding the number of participants listed in the security position listing of DTC, the principal depositary for U.S. issuers.5 For purposes of determining whether the Company has less than 300 holders of record, Rule 12g5-1 has been interpreted to mean that an issuer does not have to further “look through” DTC participants to the ultimate beneficial owners. Many companies may therefore be eligible to delist and “go dark” without management or the board of directors even being aware of the possibility.

      1. Grid, how do you distinguish among “delisted”, “going dark”, and “expert market”?

        1. Bur, Delisted is any issue that is removed from one of the exchanges and typically (though some baby bonds go to the $1000 bond desk as $25 baby bonds) goes to the OTC. Not everything on OTC is a “delisted issue” though. Some were private placed issues that got OTC tickers assigned and just trade there. For example FIISO is an OTC pink sheet that never traded on an exchange even though its common stock parent FISI does.
          Expert market is just a subsegment of the delisted issues. These cannot be traded (for reasons we all know) because the company will not report financials to OTC. If company provided delisted financials to OTC they would trade on the “OTC Pink Sheets”. Many companies provide OTC their financials so they trade freely. Many also (such as Ameren and Eversource subsidiary preferreds) freely trade on pink sheets because holding company does release financials through SEC filings despite the subsidiary preferreds being delisted.
          Concerning “going dark” and “private” the differences are a bit more nuanced. A private company in my personal terms is one that has no public tradeable common stock. Going dark means a company wants to get under shareholder limit threshold to delist their companies common stock with the intent of going “private”.
          If a company goes dark there still are some minimal shareholder protections such as right to companies financials if a current shareholder. Typically a company that goes dark is insider led, or family led where they control the votes to get this done. Theoretical worst case scenario for a company going dark is to feed the pigs at the trough and not maximize earnings per share. Such as deals done with other affiliated family companies that may benefit more the other family enterprise than itself, or hiring the lazy child a 6 figure salary to do nothing but get him out of the house, lol. In other words if you own shares of a dark company your interests and controlling entities interests may not be aligned at all.
          Some companies trade OTC through an SEC exemption created close to 100 years ago. This company only is on OTC just as a courtesy to shareholders as they were SEC exempted from having to be on an exchange.. Ever heard of this company? At $500 plus a share it has to have some worth in it, ha.


            1. There are some neat stories on a few OTC companies. Another one is Boston Sand and Gravel. BSND
              It went to expert market and they dont give a sh!§£. It has been around over a 100 years and its site has been used to film scenes in Batman, The Town, and Equalizer. Look at this pic below..The city of Boston’s highway system was built around it.
              I actually owned about 10 shares maybe 4-5 years ago at about $300 a share. I wanted to see their financials and they sent a nice little glossy without asking. I really screwed up and I should have kept them because they are now paying a $100 a year annual dividend. Boy the SEC is really saving people from owning such a crappy company, ha.

              1. Just saying.. but boston sand and gravel is not overlooked by anyone with an eye for industry. It is probably the most well known due to their large yellow sign by the highway. But anyway..

                The more interesting question is can preferred ocean spray owners request Financials? Or only common?

                1. If you find it more interesting maybe consider shooting them an email and find out. Maybe Kate can help you.

                  For corporate, business, trade, and financial media inquiries, contact:

                  Kate Leonard
                  Director, Global Corporate Communications and Culture
                  Ocean Spray Cranberries, Inc.
                  One Ocean Spray Drive
                  Lakeville-Middleboro, MA 02349
                  Email: Comms@oceanspray.com

            1. The Aztec Land & Cattle Company! Wow, there is a name I haven’t heard in decades.

              When I was a kid, I helped herd cattle on their land. Never occurred to me that they were a public company.

              I might have to buy a share just for nostalgia. I wonder whether I could get them to issue a paper certificate to hang on the wall?

    2. Also added thought I forgot to mention. Based on my understanding, a company going dark is not the same thing as going private.

      1. Thanks, Grid, for complicating a simple question! Let’s use a real-world example. SPNT and SPNT-B are listed on the NYSE. Let’s say Third Point LLC / Loeb takes the company private and delists and cancels the common shares. How can you tell if the preferred shares would be delisted *by the NYSE* for failure to comply with their minimum listing standards?

        The NYSE “Continued Listing Criteria” are specified here:


        802.01 and 802.01A state that “The Exchange would normally give consideration to the prompt initiation of suspension and delisting procedures with respect to a security of either a domestic or non-U.S. issuer when:
        802.01A.Distribution Criteria for Capital or Common Stock (including Equity Investment Tracking Stock).—
        •Number of total stockholders (A) is less than ____________________400

        So far, so good – if the number of total stockholders is over 400 after the common shares are delisted and canceled, there’s no automatic delisting of the preferred shares by the NYSE.

        The same rule also provides that “(A) The number of beneficial holders of stock held in the name of Exchange member organizations will be considered in addition to holders of record.”

        When the common shares are delisted and cancelled, the preferred shares become the primary NYSE listing. So how does one figure out how many individual unique preferred stockholders there are to assess the risk of a delisting by the NYSE, “sua sponte”, or on its own?

        That’s what I’m trying to get at. Not what happens to the (say) SPNT-B shares after a potential NYSE delisting (they could go to OTC Pink and stay liquid, or they could go to the expert market and dry up , just as you suggest).

        Outside of asking the company for the information, are unique shareholder numbers publicly available anywhere?

        1. ES, Sorry, but I have hung around 2Whiteroses too long, lol. I have got this way I guess because people (not you) get delisting and expert market mixed up to meaning the same. In terms of delisting from 300 shareholders, if every shareholder is in street name as my blurb alluded too, they are likely well under the threshold. They actually dont even have to dig further than that.
          Oddly enough some reporting OTC delisted issues actually give you pretty accurate counts. Take SOCGP as an example. Note they report over 1100 entities owning this security.
          Of course a lot of scenario’s could occur besides maintaining requirements and staying on NYSE… Even if somehow it got delisted they could report financials to OTC and it would trade fine on pink sheets.
          The blurb and link I gave above shows the reporting process one must go through. Granted its a bit heavy. But bottom line, there are 2 ways to an “accurate” share count. The way listed above where every shareholder under a single brokerage in street name is considered just 1 entity…Or you can poke deeper but it doesnt have to be done though. In fact a preferred I own specifically mentioned that. They got under 300 by redeeming any person with less than 300 shares or so not held in brokerage account. As they stated they all only counted as one person anyways and thus didnt force a tender on those people.

          1. Hey Grid – We’ve all got ’em (and I’m not talking about belly buttons) but only the most special amongst us are retentive about ’em…. lol

            1. 2WR, Have you considered rolling out of your GJP into more GJT? I just dont see the downside. You get higher yield and a better quality rated bond backstopping the synthetic adjustable. And if for some reason the counter party swaps were terminated you get a better YTM with underlying bond. And if redeemed you get the better sized cap gain. I dont see any advantage GJP has on GJT unless you see something Im missing.…GJP has a 35 bps higher adjustment, but that is more than negated by the $3 plus price differential.

              1. Grid – What you’re missing is I don’t own either one nor have I ever but will take a look….. I own GJO (Walmart) and that one’s based on 3 mo LIBOR not 3 mo treas…. That’s truly sock drawer to me. I gladly pay no mind to it and continued to own it in ZIRP days when it made no sense to continue holding Now at least it does make sense…. I’ve never owned either of GJP or GJT but I do also own GJH (US Cellular). It’s been doing poorly recently but YTM I suppose is not out of line high or low for what it is.

                1. Ok, Im sorry I forgot. I thought you owned GJP not GJO. That ‘splains it then. Too many G’s for me to remember.

        2. Im sure you could contact IR and they would give you the info. Though its probably the method I referred to which would understand the actual amount. TFIN in their annual meeting announcement (below) actually mentioned their shareholder number, so they are aware of at least what the minimum number is..
          As of February 27, 2023 we had 23,318,730 shares of Common Stock outstanding and entitled to vote at the Annual Meeting, and our shares of Common Stock were held by approximately 269 stockholders of record. Each stockholder of record of Common Stock on the record date will be entitled to one vote for each share held on all matters to be voted upon at the Annual Meeting. There are no cumulative voting rights in the election of directors.

          1. Gridbird wrote: “I’m sure you could contact IR and they would give you the info.”

            Simply FYI, asking IR for the # of unique shareholders was the first thing I did – I sent emails to Joe Nelson (head of IR at Gaslog Ltd. / Gaslog Partners) and to Dhruv Gahlaut, Chief Strategy Officer & Head of Investor Relations at SiriusPoint – but neither one has replied, and it’s been a full week in both cases. I suppose they feel no obligation to respond to me as a preferred shareholder (not a common shareholder) in both cases.

            I’ve also scoured the SEC filings looking for these numbers and struck out in both cases. SPNT is holding its annual shareholder meeting soon, and you’d think that information would be in the annual report, but if it’s there I couldn’t find it.

            All this makes me think that I am probably missing something, and my perception is that this is not something other people seem to be worried about, which adds to the concern that I’m paranoid about something that others aren’t. But these days, with 15c2-11 being what it is, getting GMLPF’d (getting removed from an Exchange, by the Exchange) is something I’d really like to avoid.

            Thank you, Grid, for the link to the SOCGP shareholder count numbers. This means these numbers exist somewhere and that it’s a matter of tracking them down. I wonder if unique shareholder numbers are available on a Bloomberg Terminal? 😉

            Speaking of Bloomberg, there’s a fascinating article in this week’s FT Magazine, “Bloomberg is contemplating life without its founder”. Here are a couple choice quotes:

            “It may not be as glamorous as many other corners of the technology world, but Bloomberg terminals have become an essential part of any self-respecting bank or investment group’s toolkit. Some executives insist on having their own as a condition for accepting a job offer. “I’ve been married to the Bloomberg terminal for longer than I have my wife,” says Steve Sosnick, chief strategist at Interactive Brokers, who has had one since he started his career at Salomon Brothers in the late 1980s. ”

            One more:
            The company’s ability to charge for the privilege of renting a terminal is the envy of the data industry. Last year, Bloomberg raised the price for just one of its terminals by about 9 per cent to $30,000 ($2,500 a month) and the cost of multiple ones to $26,580 per unit, as reported by the FT. Because the company refuses to cut deals, even for its biggest clients, and because of how rare it is to get rid of one once they’re installed, that means the annual revenues thrown off by the terminals over the next two years are easy to calculate: at least $9.7bn. 

            Free link for FT subscribers: https://on.ft.com/3ojbQdm
            Free gift link for non-FT types: https://on.ft.com/3Lxf7PH (“This link can be opened up to 3 times and is valid for 90 days.”)


            1. Es, The companies know or have access to the info. Did you see this from an earlier post?…This is from TFIN from their annual shareholder meeting that was SEC filed a few weeks ago…Notice they put the shareholder count in it….
              Stockholders Entitled to Notice and to Vote; Quorum
              Only holders of record of our Common Stock at the close of business on February 27, 2023, which the Board of Directors has set as the record date, are entitled to notice of, and to vote at, the Annual Meeting. As of February 27, 2023 we had 23,318,730 shares of Common Stock outstanding and entitled to vote at the Annual Meeting, and our shares of Common Stock were held by approximately 269 stockholders of record. Each stockholder of record of Common Stock on the record date will be entitled to one vote for each share held on all matters to be voted upon at the Annual Meeting. There are no cumulative voting rights in the election of directors.

                1. ES, you got a hard road to toe. Up into the 1990s many annual filings listed the amount of shareholders of record in the commons and the preferreds. But largely certificate issued securities are now long gone and most are in street name. So if 1000 street named shareholders owned through Schwab it would show as 1 shareholder. This is a method companies could use to go dark easier.

                  1. Grid, gentle correction: “row to hoe”, not “road to toe”. Can’t say as I’ve ever had to hoe a row of anything, but when the sun is hot and the field is wide, I expect it’s not easy…

                    1. Yes, guess your right, Bur. But I just got back from a hard 75 min walk up and down some hilly roads. And it was definitely a hard road on my toes!

    3. A shareholder asked about GMLPF during the NFE conference call:

      Michael Patterson
      My question is regarding your preferred shares on Golar LNG, the 8.75s. Some time ago, these were delisted. They’re currently not marginable. They can’t be solicited. They traded on the Pink Sheets. And I’ll give you an example. They traded about a 16% yield. Yesterday it was showing on the market about 14%. A trade went through at 11.5. And it just seems like quite a disservice to the shareholders of these preferreds to do that. Do you have any plans or what’s your comments on these preferreds?

      Christopher Guinta
      This is Chris. Why don’t you shoot me a note offline, and we can talk through this. We have put out this information publicly before and I’m happy to talk you through it. The financials are available. And we can go through it offline.

      Michael Patterson
      Well, with all due respect, for about three months, I’ve tried to call in, email and I never do get a return response on this. And so, can you address how come that they’re not listed? And would you consider listing these shares?

      Christopher Guinta
      Mike, so the shares are not listed. They were delisted when we took private the GMLP equity in 2021. We provide everything required for compliance with those shares. And we will continue to do so.

      Michael Patterson
      So you’re just fine with them trading at $0.45 on the dollar and it’s doing this to the shareholder. And like I say, I’d take it offline, but I can’t ever get a call answered, responded to at all. But it sounds like you’re just not going to do anything regarding them, right?

      Christopher Guinta
      Mike, we’re happy to look at what you’re describing. But we stay in compliance with those shares. And we provide all the information that’s required on a quarterly basis.

      1. GS – thanks for posting that exchange here. I tuned into the NFE call a little bit late this morning (5:30 Pacific) – just in time to hear that “analyst” chime in with that terrific Texas drawl of his (I put analyst in quotes because I’m pretty sure he’s not really from Morgan Stanley – happy to hear that I’m wrong though). (Reason I doubt he’s from MS is that I’ll bet it was a ploy to get on the call … I tried getting on a NFE call to ask about GMLPF a year or so ago using my own name and affiliation as a “private investor” and they wouldn’t take my question – skipped right over me.)

        His frustration was palpable, and with good reason. It would only cost NFE about $8K to get the GMLPF shares listed on OTC Markets. This would restore liquidity and GMLPF would be off this expert market BS and back to normal OTC trading status. They know this – I’ve offered to pay half the OTC filing fees to get back to pink, current status – and not one of the NFE execs have even bothered to respond to my offer. This includes CFO Chris Guinta, Cameron MacDougall their general counsel, their VP-level bean-counters and regulatory filing execs, and every single one of the many, many near-worthless “heads of IR” that have been parading through NFE’s IR department. He’s right to be frustrated.

      2. I can feel Michael’s pain and frustration…. been there/done that with NEWT and Barry Sloane on NEWTZ and NEWTL and trying to get a straight answer on their approach to addressing the continuing BDC asset coverage ratio that remains effective in their prospectuses even though they are now a BHC. I can’t get beyond “we’re in compliance.” and they no longer even publicly update what their actual asset coverage ratio is these days as they used to… Their 10q, once again, only refers to what the coverage ratio was in Dec ’22.

        1. Guinta, wanted no part of that question. I bet he was stunned when his patronizing answer to answer question offline got slapped down like a Mutombo blocked shot, ha. His “in compliance” answer had nothing to do with the question.

  8. How many “expert market” AKA EM issues are there? Yesterday I posted about Dayton and Michigan Railroad, DMRRP, but as FC pointed out, I failed to mention that is was an EM issue. I should have pointed that out in the original post and in the future will either explicitly state that an issue is EM or I will NOT post about it. I think there are a number of III’ers that are able to trade in EM issues. I thought I should have the community double check my list of EM issues. Here are the 25 EM issues that I show are currently paying dividends or interest:

    AATRL, Baby, Paying
    AFFS, Baby, Paying
    AFFT, Baby, Paying
    AFSIA, Pref, Paying
    AFSIB, Pref, Paying
    AFSIC, Pref, Paying
    AFSIM, Pref, Paying
    AFSIN, Pref, Paying
    AFSIP, Pref, Paying
    AMBKP, Baby, Paying
    AWRY, Pref, Paying
    BANGN, Pref, Paying
    CTGSP, Pref, Paying
    DMRRP, Pref, Paying
    GMLPF, Pref, Paying
    KTBA, Baby, Paying
    LTSA, Pref, Paying
    LTSF, Baby, Paying
    LTSH, Baby, Paying
    LTSK, Baby, Paying
    LTSL, Baby, Paying
    MSSEL, Pref, Paying
    OCESP, Pref, Paying
    SLMNP, Pref, Paying
    YGYIP, Pref, Paying

    I doubt that many III’ers trade EM issues that are NOT paying out, but just in case, here are the 15 that I show.

    AMTPQ, Pref, Deferred
    ATPGQ, Pref, Suspend
    CBJCL, Pref, Suspend
    CBTRP, Baby, Suspend
    COTRP, Baby, Suspend
    EHPTP, Pref, Deferred
    LEHKQ, Baby, Suspend
    LEHLQ, Baby, Suspend
    LEHNQ, Baby, Suspend
    LHHMQ, Baby, Suspend
    NUSPQ, Pref, Suspend
    PARDP, Pref, Deferred
    SKRUF, Pref, Suspend
    SMANP, Pref, Deferred
    TEUCF, Pref, Deferred

    Please speak up if I have either left an issue out and/or have it incorrectly listed. I have NOT attempted to place orders for all of these using a regular account, my data came via other methods.

  9. A Miracle, verbatim from FT

    SEC delays enforcing disclosure rule on bond markets until 2025
    Financial Times

    The US securities regulator on Wednesday said it would delay implementing a rule meant to bring transparency to corporate bond markets, bowing to fierce industry lobbying as banks and trading houses warned that enforcing the 51-year-old rule on fixed income could cause “significant, deleterious effect” on the market.

    The Securities and Exchange Commission has postponed an amendment to ‘rule 15c2-11’ until January 4, 2025, giving broker dealers in the bond market two more years to prepare themselves.

    The statute, first implemented in 1971, requires dealers to check that a wide range of financial information is up to date on each company for which they quote prices. In 2020, the SEC amended the rule, requiring dealers to ensure the details they were checking were publicly available to investors.

    Many market participants had assumed that the rule and its amendment related only to equity trading. But they had never explicitly excluded bonds — and last year the SEC decided that the rule would apply additionally to fixed income, setting off a rush among bankers and trading platforms to get ready for a dramatic shift in required disclosures.

    The Securities Industry and Financial Markets Association said on Wednesday it was “pleased the SEC has recognized the potential harm” that US companies and investors would have endured from the application of the public disclosure requirements of Rule 15c2-11 to the 144A market. The 144A market allows issuers to raise capital from qualified institutional investors, such as pension funds, without having to register their securities publicly with the SEC. It has grown rapidly in size in recent years.

    Still, “we note that the relief is not permanent,” said Kenneth E. Bentsen, Jr, president and chief executive of Sifma.

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