| The new Pink Sheets Trading Categories are a tool | | | | met the requirements for Pink Sheets Guidelines for |
| to help investors gather the information they need | | | | providing adequate current information, which means |
| on publicly traded companies quoted on the Pink | | | | they must post a quarterly letter from an attorney |
| Sheets. Since Pink Sheets is a trading venue that is | | | | regarding the completeness and adequacy of their |
| driven by OTC market trading demand, it is hoped | | | | company's disclosure. They must support a |
| that categorizing securities by their level of disclosure | | | | management certified annual audit as well. |
| will greatly enhance the capital formation process, | | | | Adequate Current Information for Banks and |
| and help prevent Micro cap fraud. | | | | International Issuers |
| The following Pink Sheets categories are a tool to | | | | Companies in this category are non-SEC-reporting |
| help investors make better informed, educated | | | | federal or state regulated banks, insurance companies |
| decisions, and are meant to improve transparency | | | | and non-U.S. companies listed on an international |
| and provide adequate public disclosure in a credible | | | | stock exchange. For banks and insurance companies, |
| and timely manner. Starting in May of 2007, every | | | | they must post to Pink Sheets the same information |
| security that Pink Sheet quotes will be put into one | | | | they provide to their regulators. Foreign issuers must |
| of the categories described below. | | | | post the same disclosures required in their home |
| Emerging Equities List: | | | | country exchange. Disclosures in a non-U.S. currency |
| The Emerging Equities List is appropriate for issuers | | | | must be clearly labeled, in English and posted in a |
| that are in development stage and are actively raising | | | | timely manner. |
| capital or companies that wish to distinguish | | | | Limited Information Available |
| themselves as issuers with reputable managements | | | | Economically distressed or bankrupt companies that |
| and audited disclosure. | | | | get quoted on Pink Sheets that have posted some |
| To qualify for this category, companies must be SEC | | | | information in the last six months, either through the |
| reporting and current in their SEC requirements and | | | | SEC or on the OTCIQ system, but whose disclosure |
| meet the Pink Sheets Guidelines for current | | | | is not current or complete. This category is also used |
| information, including GAAP audited financial reports. | | | | for companies that have not yet met the |
| Interim reports must be posted within 45 days and | | | | requirements for the Adequate Current Information |
| annual reports must be posted within 90 days after | | | | listing. |
| each fiscal year ends. The company must also | | | | No Information: |
| provide detailed information on their financial officers | | | | Companies in this category have not posted any |
| annually to Pink Sheets. | | | | information in over six months through the venues |
| SEC Current | | | | described above. In many cases, this is because the |
| The SEC Current category is for companies that are | | | | company is in financial distress or otherwise on shaky |
| SEC registered and current in their SEC financial | | | | ground. |
| reporting requirements. Companies must post their | | | | Public Interest Concern: |
| disclosure by the SEC's EDGAR system, be current in | | | | For stocks with unsolicited spam, questionable |
| their filings, file quarterly reports within 45 days and | | | | promotion or other public interest concerns will be |
| annual reports within 90 days. This level of listing | | | | listed in this category. Companies in this category are |
| requires a quarterly letter from the attorney | | | | on the verge of having their stock symbols blocked |
| vouching for the completeness of their quarterly | | | | by the Pink Sheets. |
| reports and disclosures. | | | | Only time will tell, as Micro cap fraudsters have |
| Adequate Current Information | | | | continually found ways to get around the rules, but |
| Non-SEC-reporting companies that are quoted on Pink | | | | this author believes this move by the Pink Sheets |
| Sheets that do not have GAAP audits are listed in | | | | should go a long way towards cleaning up the quality |
| this category. Pink Sheets confirms that they have | | | | of the OTC companies quoted by the Pink Sheets. |