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.: FREQUENTLY ASKED QUESTIONS

General Questions
What is the Pink Sheets?
How do I get a quote for a Pink Sheet stock?
How often are quotes updated?
If I cannot find a company on your Quote page, where else do I look?
Why is there no quote for some securities?
Where do I get real-time quotes for Pink Sheets stocks?
Why can't I get price and volume for some stocks until the end of the day?
How do the Pink Sheets differ from the OTCBB?
Who regulates the Pink Sheets?
What are the Pink Sheets' trading hours?
Where can I get historical information on Pink Sheet stocks immediately?
How do I stop getting SPAM and unsolicited faxes?
What is the best browser to use to view pinksheets.com?
Why don't I see my stock in the market statistics lists, i.e. the Most Active?
How can I advertise on pinksheets.com?

Issuer Questions
How does a company become quoted in the Pink Sheets?
How can I find a market maker to file a Form 211?
Are there any filing requirements with the Pink Sheets for the issuers?
What are the fees?
How do I get my company "delisted" from the Pink Sheets?
How are symbols assigned?
How do I get my trading symbol or company name changed?
Who do I notify about a merger, stock split or other corporate action?
How do I update my company's information on pinksheets.com?
Do financial statements have to be audited?
How can I publish a news release or financial statement on pinksheets.com?
What are the shareholder notification requirements?
How do I halt trading in my company's stock?
How can I get a list of market makers in my company's stock?
What can an issuer do to restore the display of quotes for its securities on pinksheets.com once they have been blocked for spam or promotional activities?
What is meant by the statement in paragraph 11 of the Attorney Letter Guidelines that counsel has "personally met" with management and a majority of the directors of the Issuer?

Investor Questions
What types of companies are quoted on the Pink Sheets?
Why isn't my security trading today?
How do I trade Pink Sheets stocks?
Why don't I see my order in the quotes?
Why hasn't my order been executed?
What does "Q" mean after a stock symbol?
How can I get the short interest for a Pink Sheet stock?
How can I get a list of stocks by industry, company type or price range?
What happened to my shares when the company was delisted?
Why can't I get volume during the day for some securities?
Why is the company contact information for a company on pinksheets.com missing or inaccurate?
How can I get a list of new companies and IPOs?
What happens when trading in a security is suspended by the SEC?

Market Maker/Trader Questions

Do I still have to report trades to FINRA?
What is Rule 15c2-11?
What is the piggy-back rule?
Do I have to file a Form 211 for a New York Stock Exchange or American Stock Exchange delisted security?
Do you post executions on the system?
If I want to leave my desk for a little while and don't want to close my markets, is it possible to keep them firm?
What are the quoting requirements for the Pink Sheets?
How do I withdraw from a Pink Sheet stock?
My quote has the best price yet it does not show on the inside?
What does the small "c" in front of the MMID mean?
Why don't I receive Inside Quote information for all OTCBB securities?
Are the priced quotes in the Pink Quote system considered firm by FINRA rules?
If a trader's market changes, what amount of time is considered allowable before the trader updates his or her price?
What would constitute "backing away" by dealers in the Electronic Pink Sheets?
Will Rule 6750 apply for minimum sizes in OTC Equity Securities?
If the Electronic Pink Sheets displays three active priced quotations, is a broker/dealer required to call the market makers to verify their quotations appearing on the Electronic Pink Sheets?
If a security is quoted on the Electronic Pink Sheets and the OTC Bulletin Board, will a broker/dealer have to check both quotation sources to achieve best execution for the firm's customers?
If the broker/dealer has checked all available quotable sources, obtained three or more competing priced quotes, will the broker/dealer be able to rely on the best bid/offer in executing retail transactions?

Questions About OTCQuote.com
Are the quotes on www.otcquote.com real time?
Who subscribes to www.otcquote.com?
Why should a Pink Sheet quoted company subscribe to www.otcquote.com?
Do I need to be a broker/dealer to access quotes?
What are the hours of operation for the Pink Quote system?
What types of stock/bonds are quoted on the www.otcquote.com?
What does the "U" mean in the quote montage?
How do I sign up?
If I decide to cancel my subscription agreement, can I get my money back?

Questions About OTC Dealer
What does the OTC Dealer offer the subscriber?
Is the OTC Dealer part of an order system?
What prevents an unauthorized person from using the system?
How long has the OTC Dealer been in existence?
How does the OTC Dealer work?
Can I connect to the OTC Dealer over a standard internet connection?
Is the OTC Dealer real time?
What are the hours of operation for Pink and Yellow Sheet stocks?
Do I need to be a broker/dealer to access the OTC dealer?
How do I register?
What does it cost to access the OTC Dealer?
If I decide to cancel my subscription agreement, can I get my money back?
If I currently subscribe to the paper sheets and put quotes in, do I have to subscribe to them again if I subscribe to the electronic OTC Dealer?
Do I have to connect to the OTC Dealer via the internet or is there another way?
Can I subscribe if I live overseas?
Why should I sign up for the OTC dealer?
Can I use the OTC Dealer on a trial basis before I subscribe?

  GENERAL QUESTIONS

What is the Pink Sheets?
The Pink Sheets is a centralized quotation service that collects and publishes market maker quotes for OTC securities in real-time. Pink Sheets is neither a Securities and Exchange Commission (SEC) Registered Stock Exchange nor a Broker-Dealer.

How do I get a quote for a Pink Sheets stock?
You can get a quote for any given security by entering a symbol in the input box on the left side bar located on every page of www.pinksheets.com.

How often are quotes updated?
The quotes displayed on pinksheets.com are continuously updated from 8:00 AM to 4:00 PM and are delayed at least 15 minutes. Market makers are able to update their quotes at any time during market hours.

If I cannot find a company on your Quote page, where else do I look?
You should try using the Symbol Lookup feature, located under the symbol input box, to make certain you are using a valid symbol. If you are using the correct symbol, but still get no results, then the security is not quoted on Pink Sheets. It is likely on the "grey market." Grey market securities, also called other-OTC, are only displayed on pinksheets.com if there has been a trade in the security in the previous six months.

Why is there no quote for some securities?
There are several possibilities:

1) The security is not quoted on Pink Sheets. You can verify this by checking the Primary Venue for the stock. It will be listed on the individual quote page for the respective security. If it says "Grey Market", then no market maker is publishing a quote for this stock in the Pink Sheets; it is what is known as a grey market stock.

2) There is no inside market on Pink Sheets for the security. Pink Sheets website displays inside or best bid and ask information. The inside is a calculation of the best, or highest, of all the bids and asks published by individual market makers in Pink Sheets. In order to calculate an inside market, there must be at least 2 priced bids and/or 2 priced ask quotes. There is no requirement for a market maker to publish priced quotes in Pink Sheets; they can publish unpriced quotes. If we cannot calculate an inside bid or ask, then N/A will appear in the Best Bid and Best Ask fields on the quote page of pinksheets.com.

Where do I get real-time quotes for Pink Sheets stocks?
Real-time quotes are available through our OTCQuote.com website on a password-protected subscription basis. OTCQuote.com is indispensable if you are a broker/dealer or an issuer interested in viewing real-time market maker quotes. For more information on this product, visit our OTC Quote page.

Why can't I get price and volume for some stocks until the end of the day?
All trades in OTC securities are required to be reported to FINRA via the Nasdaq ACT System within 90 seconds of the transaction. However, Nasdaq only disseminates this information in real-time for domestic OTC equities and for ADR and foreign OTC equities that are quoted on the OTCBB. For ADR and Foreign equities that are quoted on Pink Sheets or traded in the grey market, High, Low, Close and Volume are disseminated to the market place only after the close of the market for the day. Individual trades are never disseminated for these securities. There is no regulatory requirement to withhold this information from the market place; it is simply a practice of FINRA and The Nasdaq Stock Market. Pink Sheets disagrees with this practice and has requested that Nasdaq disseminate trade data for foreign equities in real time, which would allow investors the ability to better monitor the quality of their executions in these securities.

How do the Pink Sheets differ from the OTCBB?
Pink Sheets and the OTCBB are competing quotation services for OTC securities. Pink Sheets is a privately owned company, while NASDAQ operates the OTCBB. Unlike the OTCBB, issuers do not have to be fully reporting companies with the Securities and Exchange Commission (SEC) to be quoted on Pink Sheets. The Pink Sheets' OTC Dealer provides market makers with dynamic tickers and quote montages and an electronic trade negotiation system, while the OTCBB does not provide this functionality.

Who regulates the Pink Sheets?
Pink Sheets is neither a Securities and Exchange Commission (SEC) Registered Stock Exchange nor a FINRA broker/dealer. Pink Sheets is considered a Non-exclusive Securities Information Processor and an Interdealer Quotation System, for which registration is not required under current securities laws. However, Pink Sheets quotation and trading system is only open to registered broker/dealers and those broker/dealers are subject to FINRA Rules and regulations regarding their conduct and use of the Pink Sheets. Issuers are subject to Federal and State securities laws.

What are the Pink Sheets' trading hours?
Pink Sheets follows regular market hours, from 9:30 AM until 4:00 PM ET. Pink Sheets follows the market calendar of the Nasdaq Stock Market and is closed on the days that Nasdaq is closed. The Quotation system is available from 7 am to 5 pm every business day. However, individual traders at a market maker control when the trader's quotes are open and firm.

Where can I get historical information on Pink Sheet stocks immediately?
The Pink Sheets' Library Research Service offers a variety of standardized and customized research reports for the Pink Sheet securities. For more detailed information about this service click here.

How do I stop getting SPAM and unsolicited faxes?
Pink Sheets does not send, participate in the sending, nor authorize any unsolicited communications to the public, whether it's by e-mail, fax or Messenger pop-ups. However, these promotions cause damage to the Pink Sheets' reputation and we will work to track down the senders to get them, at a minimum, to include legitimate opt-out procedures on their communications. We would appreciate it if you would forward a copy of the message you received to info@pinkotc.com in order to help us in our efforts. If your complaint is regarding unsolicited faxes, please include the security being promoted, and any other pertinent details in your email.

Since the sender is not affiliated with us in any way, we are unable to remove you from this mailing or fax list. However, you can email any complaints you have of unsolicited communications and stock promotions to the Securities and Exchange Commission at enforcement@sec.gov.

The Federal Communications Commission also has an online complaint form specifically for unsolicited faxes on their website at http://www.fcc.gov/cgb/complaints.html.

The reference to Pink Sheets or our website in the message you received does not mean it is being sent by, or at the direction of, Pink Sheets. Pink OTC Markets Inc. is a quotation service for OTC securities. Because www.pinksheets.com provides quotes and other information on OTC securities, illegal stock promoters mention our website in Spam similar to mentioning www.nasdaq.com for information on a company that is listed on NASDAQ. We do not gain anything from this Spam. We do not trade stocks and we do not promote stocks, whether they are quoted on the Pink Sheets or an Exchange such as NYSE, or on NASDAQ. Our client is not the general public, only professional traders and institutional investors.

What is the best browser to use to view pinksheets.com?
Internet Explorer and Netscape versions 7.0 and up.

Why don't I see my stock in the market statistics lists, i.e. the Most Active?
Market Statistics lists include stocks quoted only on Pink Sheets. If your stock is not a unique Pink Sheets stock then it will not be listed in the market statistics lists.

How can I advertise on pinksheets.com?
Please send an inquiry regarding advertising opportunities to info@pinkotc.com.



  ISSUER QUESTIONS

How does a company become quoted in the Pink Sheets?
To be quoted on the Pink Sheets, you need to find one market maker willing to quote your company's stock. Only SEC-registered broker-dealers (market makers) that are members of the National Association of Securities Dealers (NASD) can quote securities in the Pink Sheets. For more information, see: How Does a Company Become Quoted on the Pink Sheets?

How can I find a market maker to file a Form 211?
Pink Sheets cannot recommend specific market makers. However, market makers listed in our Service Provider Directory welcome potential issuers to contact them to discuss making a market in their company's stock. For more information on Rule 15c2-11 and the Form 211, see: What is Rule 15c2-11?

Are there any filing requirements with the Pink Sheets for the issuers?
Issuers are not required to register securities with the Securities and Exchange Commission (SEC), or be current in their reporting requirements to be quoted on the Pink Sheets. Nor are issuers required to file financial or other company information with the Pink Sheets. SEC Rule 10b-17 requires all issuers of publicly traded securities, including Pink Sheets securities, to notify the NASD at least 10 calendar days prior to the record date of any dividend or other distribution, stock split, reverse split, or rights or subscription offering.

What are the fees?
The Pink Sheets does not charge issuers a fee for being quoted on the service. Market makers are charged for each security in which they make a market in the Pink Sheets

How do I get my company "delisted" from the Pink Sheets?
Because securities are not "listed" on the Pink Sheets, it is not possible for an issuer to "delist" them. The only way to remove a company from the Pink Sheets is for all of the market makers to stop quoting it. If your company's securities no longer actually exist, but are still being quoted, you should contact Nasdaq's Market Integrity Department at 203-375-9609 and provide them documentation to that effect. Nasdaq will investigate and, if appropriate, eliminate the trading symbol and advise the Pink Sheets. Pink Sheets will then remove the market makers quotations in this security.

How are symbols assigned?
Nasdaq assigns all OTC security symbols.

How do I get my trading symbol or company name changed?
You should contact Nasdaq's Market Integrity Department at 203-375-9609.

Who do I notify about a merger, stock split or other corporate action?
You should contact Nasdaq's Market Integrity Department at 203-375-9609. Nasdaq will then notify us of the changes.

How do I update my company's information on pinksheets.com?
Complete the Company Information Update Form

Do financial statements have to be audited?
Current NASD rules do not require the financial statements of Pink Sheet issuers to be audited, but they should be prepared in accordance with GAAP or, for foreign issuers, in accordance with their home country's accounting standards.

How can I publish a news release or financial report on pinksheets.com?
There is an annual fee of $3000, which permits subscribers to post unlimited Financial Reports throughout the year; there is a per release fee of $100 to publish news releases through the Pink Sheets News Service. A one-time $500 account verification and set up fee applies. To subscribe to this indispensable service, please download the Subscription Agreement and fax to 212-652-5920 or E-mail to issuerservices@pinkotc.com. For more information, see Pink Sheets News Service

What are the shareholder notification requirements?
Pink Sheets has no shareholder notification or shareholder approval requirements.

How do I halt trading in my company's stock?
Only the NASD or the SEC can halt trading in OTC securities. The NASD does not have the authority to halt trading for the dissemination of OTC issuer news.

How can I get a list of market makers in my company's stock?
You can request a list of market makers in your company's stock by sending an email to issuerservices@pinkotc.com.

What can an issuer do to restore the display of quotes for its securities on pinksheets.com once they have been blocked for spam or promotional activities?
The issuer must provide certain disclosure to investors via the Pink Sheets News Service (http://www.otciq.com). The disclosure must comply with Pink OTC Markets' Guidelines for Providing Adequate Current Information (PDF). Pink OTC Markets, at it's discretion, may continue to temporarily block the dissemination of quotes for securities of companies that have provided the required disclosure if we continue to get complaints about spam or other unsolicited communications promoting the issuer's stock.

What is meant by the statement in paragraph 11 of the Attorney Letter Guidelines that counsel has "personally met" with management and a majority of the directors of the Issuer?

This statement describes the process used by competent counsel to perform the work necessary to submit an honest and reliable letter with respect to the issuer's disclosure ("Information")posted through the OTC Disclosure and News Service. This process requires counsel to assist the issuer by participating directly in drafting the Information required under Pink OTC Markets' Guidelines for Providing Adequate Current Information. In drafting this disclosure, the attorney will examine the evidence that supports each material statement made in the Information. Some of this evidence will be physical or documentary, while other evidence will consist of oral statements made to the attorney by executive officers who participated in or directed the events described in the Information. We believe that it is essential for the attorney to interview these officers personally to confirm the material facts described in the Information and clear up discrepancies in the evidence at hand. The attorney will then discuss the Information with the members of the issuer's board of directors to confirm and correct the disclosure, where necessary, so that it is a correct statement of all material facts regarding the issuer and its securities.

These tasks cannot be performed adequately unless the attorney has actually met "face-to-face" with executive management, including those persons actively involved in the matters described in the Information, and each member of the Board of Directors. A personal meeting enables the attorney to assess the demeanor and credibility of these "witnesses" and supports, or in some cases, raises doubts, as to their testimony and recollection of events. It is also our experience that people are more candid when discussing matters with persons they have personally met.

Actual discussions regarding the matters disclosed in the Information can take place by telephone, email or other mediums, provided that the attorney on prior occasions has actually met face-to-face with each member of the issuer's executive management and board of directors, and on the basis of those meetings, believes that these other mediums of communication will be adequate to confirm the reliability of the Information.



  INVESTOR QUESTIONS

What types of companies are quoted on Pink Sheets?
There are a wide variety of companies quoted on Pink Sheets. There are small companies that cannot or do not wish to meet the listing requirements of the exchanges; there are many large foreign issuers that are listed on an exchange in their home country but traded OTC in the US market (often because their financial statements are not prepared according to GAAP, which is a requirement for US listing); many Pink Sheets companies were formerly listed on an exchange and fell below the required standards for listing; due to the increased compliance costs associated with the Sarbanes/Oxley legislation, some listed companies have voluntarily delisted from exchanges and chosen to be traded over-the-counter; and there are a number of banks and other issuers that are thinly traded and so choose not to go to the expense of listing on an exchange.

Why isn't my security trading today?
There are many thinly traded stocks on Pink Sheets that are not traded every day.

How do I trade Pink Sheets stocks?
You must open an account with a broker to trade Pink Sheets stocks. The Pink Sheets itself is not a broker and does not provide a trading service to investors. For more information on trading Pink Sheets stocks, see: How to Buy or Sell Pink Sheets Stocks.

Why don't I see my order in the quotes?
Pink Sheets securities are not subject to Limit Order Display requirements. A market maker is not required to reflect a customer's order in its published quotation.

Why hasn't my order been executed?
You need to ask your broker this question. Brokers hold customer orders in their proprietary order books and only they can tell you specifically why it has not yet been filled. Possible explanations include: the order may not yet be marketable or if it is/was marketable, other customer orders at the same price may have been in the order book longer than yours and gotten executed first.

What does "Q" mean after a stock symbol?
In the fifth character of a symbol, "Q" means the issuer of the security is involved in bankruptcy proceedings.

How can I get the short interest for a Pink Sheets stock?
FINRA rules require that market participants report their short interest in non-Nasdaq OTC securities every 15 days. In order to access short interest data, please visit the following link to our website: http://www.pinksheets.com/pink/marketactivity/short_interest.jsp.

How can I get a list of stocks by industry, company type or price range?
This information is not currently available. We are planning a future enhancement to www.pinksheets.com that will permit users to search for securities based on these types of criteria. The statistics that we do currently track are available in the Trading Statistics section of our website.

What happened to my shares when the company was delisted?
If your stock was delisted from another market and is now quoted on Pink Sheets, nothing has changed with the shares themselves. You are still the registered owner of the securities and can trade them. You should check with your current broker to make certain that they will trade Pink Sheets stocks. If not, you will need to locate a broker that does trade Pink Sheets stocks. There is a list of some of these brokers at the bottom of the page in How to Buy and Sell Pink Sheet Stocks.

Why can't I get volume during the day for some securities?
All trades in OTC securities are required to be reported to FINRA via the Nasdaq ACT System within 90 seconds of the transaction. However, Nasdaq only disseminates this information in real-time for domestic OTC equities and for ADR and foreign OTC equities that are quoted on the OTCBB. For ADR and Foreign equities that are quoted on Pink Sheets or traded in the grey market, High, Low, Close and Volume are disseminated to the market place only after the close of the market for the day. Individual trades are never disseminated for these securities. There is no regulatory requirement to withhold this information from the market place; it is simply a practice of FINRA and The Nasdaq Stock Market. Pink Sheets disagrees with this practice and has requested that Nasdaq disseminate trade data for foreign equities in real time, which would allow investors the ability to better monitor the quality of their executions in these securities.

Why is the company contact information for a company on pinksheets.com missing or inaccurate?
Pink Sheets issuers are not required to maintain current address or contact information with Pink Sheets. Pink Sheets does not have a listing agreement with its issuers and no other mean of compelling companies to provide this information to us, although many do so voluntarily. Pink Sheets has a relationship with the broker/dealers that quote the stocks, not with the issuers of the stocks themselves.

How can I get a list of new companies and IPOs?
Pink Sheets is only for seasoned securities; there are no IPOs in this market. You can get a list of securities that are new to Pink Sheets for the previous 7 days at the Market Data section of our website.

What happens when trading in a Pink Sheet security is suspended by the SEC?
SEC suspensions last 10 days for OTC securities. When a security is suspended, Pink Sheets removes all market makers and their quotes from the system and displays a "Halted/Suspended" message. After 10 days, market makers may re-enter the stock if they comply with Rule 15c2-11, which requires filing a new From 211, which must include the issuers' current financial information.



  MARKET MAKER/TRADER QUESTIONS

Do I still have to report trades to the NASD?
Yes, you are responsible for reporting trades through ACT. Pink Sheets offers a number of services that enables you to automate the reporting process. You can get FIX drop copies messages to integrate into your in-house systems, we can deliver drop copies to a third party such as Brass or we can submit drop copy executions directly to ACT on your behalf.

What is Rule 15c2-11?
Securities and Exchange Act of 1934 (Exchange Act) Rule 15c2-11 governs the submission and publication of quotations by brokers and dealers for certain non-Nasdaq over-the-counter equity securities. Specifically, the rule applies to a broker/dealer's initiation or resumption of quotations for such securities in any inter-dealer quotation medium, including the OTC Bulletin Board and the Pink Sheets. 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 Rule 15c2-11. Get a copy of the Form 211.

What is the piggy-back rule?
It means that a security is piggyback eligible under Rule 15c2-11. Market makers can quote the stock immediately without being required to file a Form 211.

Do I have to file a Form 211 for a New York Stock Exchange or American Stock Exchange delisted security?
Yes. Prior listing on NYSE or AMEX does not exempt a Market Maker from filing. However if the security was quoted on the Pink Sheets prior to the delisting, it may be already "piggyback" eligible.

The following interpretations of NASD Rules regarding Firmness of Quotations and Best Execution were provided by NASD Regulation in a letter to Pink Sheets dated April 28, 1999.

Do you post executions on the system?
No, the OTC Dealer does not post executions. For OTC equity securities, trades are reported to the NASD via the ACT system. In OTC bonds, there is no trade reporting facility, so no one sees a completed trade except you and your counter-party.

If I want to leave my desk for a little while and don't want to close my markets, is it possible to keep them firm?
Yes, you may temporarily exit the system without affecting your markets, however you are still liable under NASD Rules to trade at you published prices if your quotes are open.

What are the quoting requirements for the Pink Sheets?
You must be a registered broker/dealer with the NASD.

How do I withdraw from a Pink Sheet stock?
Users of the OTC Dealer can withdraw any quotes at any time using the "withdraw quote" command.

My quote has the best price, yet it does not show on the inside?
The Inside quote is calculated using only the quotes of traders who have opened their positions. Every trader has to open and close his/her markets every day.

What does the small "c" in front of the MMID mean?
It means that the trader has closed his/her markets and the quote is not considered firm. Closed quotes are not used to calculate the inside market.

Why don't I receive Inside Quote information for all OTCBB securities?
Only Pink Sheet and Yellow Sheet Market Maker quotes are displayed on the Dealer and OTC Quote. The OTC Dealer will integrate OTCBB quotes in the near future.

Are the priced quotes in the Pink Quote system considered firm by FINRA rules?
NASD Rule 3320 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. IM-3320 provides further that

[m]embers and persons associated with members in the over-the-counter market make trading decisions and set prices for customers upon the basis of telephone and wire quotations as well as quotations in the National Quotation Bureau sheets. In some instances a dealer's quotations, purportedly firm, are, in fact, so qualified upon further inquiry as to constitute "backing away" by the quoting dealer. Further, dealers who place quotations in the sheets have been found to be unwilling to make firm bids or offers upon inquiry in such a way as to pose a question as to the validity of the quotations originally inserted. Such "backing away" from quotations disrupts the normal operation of the over-the-counter market.

Members, of course, change inter-dealer quotations constantly in the course of trading, but under normal circumstances where the member is making a "firm trading market" in any security, it is expected at least to buy or sell a normal unit of trading in the quoted stock at its then prevailing quotations unless clearly designated as not firm or firm for less than a normal unit of trading when supplied by the member. . . (emphasis added).

Accordingly, for purposes of compliance with NASD Rule 3320, unless designated as a non-firm quotation by the broker-dealer or by the rules of the 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.

If a trader's market changes, what amount of time is considered allowable before the trader updates his or her price?
Although the SEC firm quote rule, Rule 11AC1-1(c), does not apply to transactions in OTC eligible securities, its provisions and exceptions should be considered in providing guidance and responding to this question. SEC Rule 11Ac1-1(c) provides that a market maker must execute an order "presented" to it at a price at least as favorable as its published quotation up to its published quotation size. Exceptions to Rule 11Ac1-1 exist only if: (1) the market maker revises its quoted price or size prior to the order being presented; or (2) the market maker has effected or is in the process of effecting a transaction at the time an order is presented and immediately upon completion of that transaction communicates a revised quotation (the trade ahead exception). A trade-ahead exception for trades that are reported after the presentment of an order will not be permitted if a market maker executes a trade and changes its quote absent proof, such as the time of order entry, that the market maker was in the process of executing the order prior to presentment of the order and the market maker immediately updated its quote subsequent to the execution. These same concepts also apply to members' responsibilities under Rule 3320 with respect to quotes and transactions in OTC equity securities.

What would constitute "backing away" by dealers in the Electronic Pink Sheets?
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 and no exception from the firm quote rule applies.

Will Rule 6750 apply for minimum sizes in OTC Equity Securities?
Yes. Rule 6750 provides that every member firm that functions as a market maker in OTC Equity Securities by entering firm quotations into the OTC Bulletin Board Service (OTCBB) (or any other inter-dealer quotation system that permits quotation updates on a real-time basis) must honor those quotations for the minimum size as defined by the rule. In this regard, it is the market maker's responsibility to determine the minimum size requirement applicable to its firm bid and/or offer in each of its registered securities (excluding OTC Equity Securities for which the OTCBB will not accept firm quotations).

Because the Electronic Pink Sheets is an inter-dealer quotation system that permits quotation updates on a real-time basis, the minimum quote size requirements would apply equally to securities quoted on that system.

If the Electronic Pink Sheets displays three active priced quotations, is a broker/dealer required to call the market makers to verify their quotations appearing on the Electronic Pink Sheets?
NASD Notice to Members 92-50, Question #41 provides that if the OTC Bulletin Board displays three firm quotations in a particular security, than a member does not have to call the market makers to verify their quotations appearing on the OTC Bulletin Board pursuant to Article III, Section 1 and 21 (b) of the NASD Rules of Fair Practice (currently NASD Conduct Rules 2320 and 3110). A broker/dealer need only note on the order ticket the identity of the broker/dealers and the firm quotations obtained from the OTC Bulletin Board. Because the Electronic Pink Sheets will be an inter-dealer quotation system that permits quotation updates on a real-time basis, the same reasoning should be applied so that a broker/dealer need only note on the order ticket the identity of the broker/dealers and the firm quotations obtained from the Electronic Pink Sheets.

If a security is quoted on the Electronic Pink Sheets and the OTC Bulletin Board, will a broker/dealer have to check both quotation sources to achieve best execution for the firm's customers?
Yes. Best execution requires that a firm make use of all technology reasonably available to it and when reliable, take into consideration superior priced orders that are resident in electronic systems that reasonably and readily accessible. Since both systems would be readily available to most broker/dealers, a broker-dealer should review the quotations on both quotation systems before executing a customer transaction.

If the broker/dealer has checked all available quotable sources, obtained three or more competing priced quotes, will the broker/dealer be able to rely on the best bid/offer in executing retail transactions?
Not necessarily. Best execution is a facts and circumstances analysis which involves more than just checking markets to determine the best bid and/or offer. The factors to be considered include, but are not limited to, speed of execution, volatility, relative liquidity, pressure on available communications, the size and type of the transaction, the number of primary markets checked and the location and accessibility of primary markets and quotation sources. Based on the above, executing transactions at the "inside" quotation reflected on the Electronic Pink Sheets would not necessarily mean the broker-dealer met its best execution obligations, just as is the case with transactions in securities quoted in the OTCBB.



  QUESTIONS ABOUT WWW.OTCQUOTE.COM

Are the quotes on www.otcquote.com real-time?
Yes, but your browser is not automatically updated after you have received a quote. To get the latest quote, you must push the "refresh" button on your browser.

Who subscribes to www.otcquote.com?
Any individual or broker dealer interested in real-time Pink Sheets and Yellow Sheets quotations should subscribe.

Why should a Pink Sheet quoted company subscribe to www.otcquote.com?
A Pink Sheets quoted company should subscribe to keep track of prices and market-maker activity.

Do I need to be a broker/dealer to access quotes?
No. OTCQuote.com enables you to view in real-time the inside quotes (price and size), market maker quotes (price and size) and market maker contact information and security lookup by name, symbol or CUSIP. However, you must be a broker/dealer to subscribe to the OTC Dealer and make markets.

What are the hours of operation for the Pink Quote system?
The service operates 10 hours a day, between 7 a.m. to 5 p.m. every business day. OTCQuote.com should be accessible 22 hours per day from 2 a.m. to 12 a.m., except when the service is down for maintenance and upgrades.

What types of stock/bonds are quoted on the www.otcquote.com?
Domestic and foreign stocks as well as corporate and trust bonds.

What does the "U" mean in the quote montage?
If there is a lowercase "u" next to the market maker symbol, it means the quote represents an "unsolicited" customer order. An uppercase "U" in the price column means an "unpriced" quote (market maker shows interest in trading but does not publish a price).

How do I sign up?
Please contact the Pink Sheets sales department by phone at (212) 896-4410, or by e-mail at sales@pinkotc.com

If I decide to cancel my subscription agreement, can I get my money back?
To cancel a subscription, please send customer service a letter requesting cancellation with a 30-day notice and you will be refunded for the months you haven't used if there is no open balance on your account.



  QUESTIONS ABOUT OTC DEALER

What does the OTC Dealer offer the subscriber?
The OTC Dealer gives users full access to tickers, quote montages and multiple watch lists for Pink Sheets and Yellow Sheets, a quotation service for all taxable debt. The OTC Dealer's true point-and-click functionality allows market makers to dynamically manage their quotes and to make markets. Market makers can submit one sided or two sided priced quotations, as well as un-priced or OW/BW indications of interest.

Is the OTC Dealer part of an order system?
No, the OTC Dealer is an informational quote system.

What prevents an unauthorized person from using the system?
Each user must have a secure User ID and Password in order to enter the system.

How long has the OTC Dealer been in existence?
The electronic OTC Dealer was launched September 15, 1999.

How does the OTC Dealer work?
The Dealer application is written in Java, a computer language that allows programs to operate independently of computer hardware or operating systems. Java Runtime Environment (JRE) that supports Java version 1.2 or Java 2 is required to run the Dealer application. The Dealer install application includes a Java Runtime Environment. Learn more about hardware requirements.

Can I connect to the OTC Dealer over a standard internet connection?
Yes.

Is the OTC Dealer real time?
Yes. The OTC Dealer allows broker/dealers to view real-time quote updates and dynamically manage their quotes.

What are the hours of operation for Pink and Yellow Sheet stocks?
The Dealer is open 12 hours per day. The service is available between 6am and 6am every business day. However, individual traders at a market maker control when the trader's quotes are open and firm.

Do I need to be a broker/dealer to access the OTC dealer?
Yes, you must be a registered broker/dealer to access the OTC Dealer.

How do I register?
Please contact our sales and marketing department:
Phone: 212-896-4410
Email: sales@pinkotc.com

What does it cost to access the OTC Dealer?
The OTC Dealer Application costs $250.00 per month per Authorized User. There are discounts available for more than 5 users. View the Pricing Schedule.

If I decide to cancel my subscription agreement, can I get my money back?
Yes. You must fax customer service requesting a cancellation and you will receive a refund check for the months you haven't used provided there is no open balance on your account.

If I currently subscribe to the paper sheets and put quotes in, do I have to subscribe to them again if I subscribe to the electronic OTC Dealer?
No. Please call customer service toll-free at (800) 732-7868, ext. 434, if you have further questions.

Do I have to connect to the OTC Dealer via the internet or is there another way?
IXnet is a network service provider which can provide a dedicated connection to the Pink Sheets. Connecting via the IXnet Liquidity Network requires a circuit charge. Please contact Mona Wachtel at (212) 412-6479 with any questions.

Can I subscribe if I live overseas?
You may only subscribe to the OTC Dealer if you are a United States SEC registered broker dealer. If not, you may subscribe to www.otcquote.com.

Why should I sign up for the OTC dealer?
You should subscribe if you are a broker/dealer that wants to manage his/her market quotes, as well as show un-priced or OW/BW indications of interest.

Can I use the OTC Dealer on a trial basis before I subscribe?
Yes, Please contact our sales and marketing department:
Phone: 212-896-4410
Email: sales@pinkotc.com



  CONTACT INFORMATION

If you have questions not covered in these sections, please contact us.

General Information and Investor Questions info@pinkotc.com

Issuer Questions
Issuer Services 212.896.4420 issuerservices@pinkotc.com

Subscription Information
Customer Service 212.896.4405, option 2 sales@pinkotc.com

Trial Subscriptions
Sales Marketing 212.896.4432 sales@pinkotc.com

Historical Pricing
Library 212.896.4483

Technical Information
Systems Department 212.896.4411

Glossary