OTCEI offers two main pathways for companies without existing market quotes to gain trading access:
OTCEI Initial Review
Eligibility: Private companies, foreign-listed firms, previously non-compliant companies, and Grey Market securities.
Process: OTCEI conducts a review of financials, governance, and disclosures. For OTCQB-tier applicants, this is part of the application process.
Broker-Dealer Facilitated (U.S. Model)
For: Shell companies (or those with shell-like attributes) and companies with less than 10% public float.
Process: A broker-dealer files Form 211 with FINRA to confirm compliance with SEC Rule 15c2-11 (financial audits, minimum shareholders, public float verification).
Note: This process is required for U.S. compliance and is referenced here as a global best practice; Indian companies must follow SEBI and OTCEI regulations.
Key Points:
Shell companies may require restructuring.
Corporate governance (independent directors, audit committee) is required for premium tiers.
Minimum bid price and public float requirements apply for OTCQB-equivalent tiers.
All companies must comply with SEBI and OTCEI guidelines for Indian market access.
