Listing: your venue's obligations

What Listing covers

Listing is the one page for the obligations your trading venue and your EDGAR account set, none of them SEC filings.

It covers your standing with the venue, the recurring checkpoints its rules require, the notices owed around a corporate action, the letters the venue sends, and the yearly EDGAR account confirmation.

The sidebar item carries the venue's name (Nasdaq, NYSE, NYSE American, Cboe, OTCQX, OTCQB or OTCID) and appears once the company profile names one. Pink Limited and Expert Market companies, and a company whose profile names no venue, keep their calendar rows and have no Listing page.

Every row here is also on the Company calendar; the CIK, the CCC and the EDGAR delegation stay in Settings › EDGAR.

Standing and checkpoints

Standing reads Good standing or Deficiency with its cure date from the letters you record; until a letter is recorded it reads Standing not recorded. TakePublic does not sign in to OTCIQ, the Listing Center or Listing Manager and never changes standing on its own.

Each checkpoint names the rule it rests on and the date that rule was read, opens the venue's portal for the act, and Mark as done records that you did it.

• OTCQX, OTCQB and OTCID: the management certification within 45 calendar days after the annual report's due date, the OTCIQ profile verification at least every six months, and the annual fee. OTC Markets accepts the certification only when the profile was verified within the previous 30 days.
• OTCQX adds the annual fee due December 1 for the coming year and an annual shareholder meeting each calendar year.
• Nasdaq: the annual meeting no later than one year after fiscal year end (Rule 5620(a)) and the January fee invoice, whose date you enter.
• NYSE: the annual meeting during each fiscal year (302.00), the annual written affirmation and CEO certification within 30 days after the meeting (303A.12), and an interim affirmation within five business days of a board or committee change.
• NYSE American: the meeting within one year after fiscal year end (704) and the same affirmations.
• Cure periods: OTCQX and OTCQB allow 30 calendar days (45 for late periodic reports), with 90 on OTCQX for bid price, market capitalization or market makers and 90 on OTCQB for bid price or public float; OTCID has no cure period, removal is immediate; Nasdaq allows 45 days for a plan on most standards and 180 calendar days on bid price; NYSE American allows a plan of up to 18 months.

NYSE affirmations

NYSE and NYSE American companies send an Annual Written Affirmation with the Annual CEO Certification through Listing Manager no later than 30 days after the annual meeting (30 days after the 10-K when no meeting is held). The row appears once the meeting date is known from the proxy season, a company event or the Item 5.07 8-K.

An Interim Written Affirmation is due within five business days of a change to the board or its committees; a change inside the 30 days after the meeting rides in the annual one. TakePublic opens the interim row from an Item 5.02 8-K.

Corporate actions

A dividend or distribution, a stock split or reverse split, or a rights offering is a Rule 10b-17 action: FINRA (for an OTC-quoted security) or the exchange must hear about it no later than 10 days before the record date. A name or symbol change goes to FINRA (Rule 6490(b)(3)), NYSE and NYSE American 10 calendar days before it takes effect; Nasdaq's event form asks the same, though Rule 5250(e)(3) allows notice up to 10 days after.

OTCQB and OTCID companies notify FINRA at least 10 business days before the record date, the stricter term their rules set; OTCQX and the exchanges use 10 calendar days.

FINRA's fee under Rule 6490(c) for a Rule 10b-17 notice is $200 when timely; a late one is $1,000 when filed at least five calendar days before the corporate action date, $2,000 at least one day before, and $5,000 on or after it. A voluntary symbol change is $500. Unpaid late fees accumulate on the symbol, and FINRA processes no voluntary symbol change until they are paid. TakePublic shows the ladder as rule text, never as an amount you owe.

Confirming a suggestion or recording an action opens its notice rows on the calendar. The follow-on facts (the FINRA case reference, the Daily List publication date, the new symbol and CUSIP, the transfer agent instruction, DTC eligibility) are recorded on the action's sheet and open no row.

Venue letters

Record each letter from the venue with its date, the rule it cites and the cure date it names. A deficiency notice, public reprimand or delisting determination moves standing to Deficiency and opens a Regain compliance row due on the cure date; a compliance-regained letter returns standing to Good standing and settles the row.

Nasdaq Rule 5810(b) has the company announce a deficiency notice, delisting determination or public reprimand by press release or 8-K no later than four business days after receipt.

SEC account

Once a year an account administrator confirms the company's EDGAR account on the EDGAR Filer Management dashboard by the quarter end the dashboard shows (Mar 31, Jun 30, Sep 30 or Dec 31, or the next business day when EDGAR is closed). Confirming in an earlier quarter moves the due date to one year after that quarter.

A missed confirmation starts a three-month grace period with daily reminders from EDGAR; after it the account is deactivated and a new Form ID is needed, with the prior individuals and delegations removed.

The CIK Confirmation Code itself is entered and tested in Settings › EDGAR, never here.

What a past-due checkpoint means

A checkpoint past its date carries the Late stamp until you mark it done. Nothing is filed and no penalty runs from TakePublic; the venue's own consequence follows its rules: a compliance flag and a cure period at OTC Markets, a deficiency letter and a plan period at an exchange, and for the EDGAR confirmation the SEC's grace period.