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FINRA Rule 6490 and OTC corporate actions
An OTC reverse split, name change or dividend takes effect only when FINRA processes it.
- Applies to
- Non-exchange-listed securities
- Dividends and splits
- Notice 10 days before the record date
- Name and symbol changes
- Notice 10 calendar days before effect
- Timely fee
- $200; late fees up to $5,000
- Effective when
- Published on the OTC Daily List
How an action reaches the market
- 01Board approves
- 02Notice to FINRA
- 03FINRA reviews
- 04Daily List entry
- 10b-17 actionsDividends and other distributions, stock splits, reverse splits, rights and subscription offerings: notice no later than 10 days before the record date (Rule 6490(b)(2); Rule 10b-17(b)(1)).
- Other actionsName changes, symbol changes, mergers, acquisitions, dissolutions, control transactions, bankruptcy or liquidation: a complete request no later than 10 calendar days before the effective date (Rule 6490(b)(3)).
- Exchange-listedExchange-listed companies follow their exchange's notice procedures instead.
The fee schedule
Paragraph (c) of the rule, as amended effective October 7, 2025. Fees are non-refundable and unpaid late fees accumulate against the symbol.
- Late notices$1,000 if at least 5 calendar days before the action date, $2,000 if at least 1 calendar day before, $5,000 on or after.
- Symbol set-upInitial symbol set-up and symbol deletion carry no charge.
- Unpaid late feesFINRA will not process a voluntary symbol change until every accumulated late fee on that symbol is paid (Supplementary Material .01).
What FINRA reviews, and when it refuses
- Complete documents and authorityThe signed request, board resolutions, state filings for a name change or split, and any information FINRA asks for. A request that goes 90 calendar days without a sufficient response lapses.
- Current in SEC reportingOne of the five deficiency factors is that the issuer is not current in its reporting requirements to the SEC or other regulator. A late 10-K can stall a reverse split.
- Regulatory historyPending or settled regulatory actions, or fraud concerns, about the issuer, its officers, directors, transfer agent, counsel or promoters can also produce a deficiency determination.
- AppealWithin seven calendar days of the notice, to a three-member subcommittee of the Uniform Practice Code Committee, with the $4,000 fee. The appeal stays processing until decided.
CUSIP, symbol and the Company calendar
- New CUSIPA name change or reverse split usually requires a new CUSIP from CUSIP Global Services before FINRA processes the action.
- SymbolA reverse split typically carries a temporary fifth character for 20 business days; a voluntary symbol change is a separate $500 request.
- On the Company calendarCorporate actions are not computed from EDGAR. Add the notice date and effective date with the dates counsel sets; the 8-K clock, four business days after the trigger, runs on the same calendar.
Frequently asked questions
How far in advance must an OTC company notify FINRA of a reverse split?
A reverse split is an SEA Rule 10b-17 action: notice no later than 10 days before the record date. Notice inside that window is late and pays $1,000, $2,000 or $5,000 depending on how late.
How far in advance for a name or symbol change?
Other company-related actions need a complete request at least 10 calendar days before the effective date. A voluntary symbol change costs $500.
What does a Rule 6490 filing cost?
$200 for a timely 10b-17 notice. Late notices cost $1,000 if at least 5 calendar days before the action date, $2,000 if at least 1 day before, and $5,000 on or after. Symbol set-up and deletion are free; an appeal is $4,000.
Can FINRA refuse to process an action?
Yes. Deficiency factors include incomplete or unauthorized documents, an issuer not current in its SEC reporting, regulatory actions involving the issuer or its people, fraud concerns, and settlement uncertainty. The determination can be appealed within seven calendar days.
Does Rule 6490 apply to Nasdaq or NYSE companies?
No. It applies to non-exchange-listed securities. Listed companies give notice under their exchange's rules, for example Nasdaq's dividend notice 10 calendar days before the record date and reverse split notice five business days before the market effective date.
Official sources
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