OTC Markets Group Inc. (OTCM) Earnings Call Transcript & Summary

Hello, everyone. I'm Bob Power, Senior Vice President of Corporate Services at OTC Markets Group. Welcome to all of you, and thanks to all of you for joining our OTC Markets educational webinar, 1 year on, a review of the impact and outcomes of SEC Rule 15c2-11. Before we begin the webinar, I'm just going to give you a few housekeeping items. All participants will be on mute. The presentation will last about 30 minutes, after which there will be 10 to 15 minutes Q&A session. [Operator Instructions] If we can't get to your question, we'll reach out directly to you after the webinar. This webinar will be recorded and a link will be e-mailed to all registrants along with a copy of the presentation. A copy of this webinar will also be archived on the OTC Markets website. And now to the next slide. I would like to welcome our guest speakers from OTC Markets Group, Jason Paltrowitz, Executive Vice President of Corporate Services; Chris King, Senior Vice President, Corporate Services International; Joe Oltmanns, Senior Vice President, Corporate Services, U.S.; and Dr. Rory Knight, Chairman of Oxford Metrica. We'll go right into the next slide. Jason, we'll start with you. Let's just go right to you, and let me ask you, 1 year ago, 2-11 reform occurred. What was it? Why did it happen? And why was it important?

Sure. Thanks, Bob, and thanks for everyone joining. Probably a good idea, and thanks for asking that. We kind of set the stage a little bit as to what Rule 15c2-11 was, is, and how it's changed. So in its purest and simplest form, 15c2-11 were the rules that governs the quotation of securities in the over-the-counter market and required that broker-dealers do a base level of due diligence about an issuer before they quoted that security. So up until the amendment or the rule change what that meant in practice was that if a market maker or a broker-dealer wanted to quote a security, either for them to be able to trade that security or to fulfill an order by a client, he, she, the firm would have to file a paper form 15c2-11. In many cases, they would include the annual report or latest financials and disclosure of that issuer, and would basically attest to the fact that they've done that level of due diligence and the company was eligible financially okay enough to have a public quotation of the security. What would then happen after 30 days, there was this concept of piggybacking, which meant that other market makers could quote that security based on, I'll call it, an [ attestation ] or the filing from the original corporate dealer. And those quotes could remain in perpetuity. There was no requirement for anybody to do any sort of look forward or maintain that level of public disclosure. So long as somebody was quoting that security, it could remain quoted in perpetuity, irrespective of the level of disclosure that those companies were performing going forward. So what that meant in practice was you had a lot of companies that were dark or distressed that weren't current in their filings that weren't making information available. On the international side, you had companies that warrant -- didn't meet the foreign private issuer exception. There was really no method to maintain looking at that level of disclosure on a go-forward basis. So the rule hadn't been amended in about 30 years. And so what the SEC basically said was a couple of things. One, we've entered the Internet age. And so the filing of paperwork seems silly as that information is now much more readily available electronically. And what we want to do is not only have this initial requirement that have an ongoing requirement. So it wasn't enough to just file once, but we -- what SEC wanted to make sure that there was this constant information being fed into the system. And that somebody was looking at it and reviewing it to make sure that those securities could continue to be "eligible." What they also did was they changed the rule to allow for what's called interdealer quotation systems, such as OTC Link as you see here on the screen, we could become qualified to initially quote those securities and to be the holder or reviewer of the disclosure to maintain the eligibility either from an initial or an ongoing basis. So what it did was it took those 12,000 securities, and it basically created the criteria changing a little bit who could do the initial. So again, bringing in this concept of an interdealer quotation such as us, not just the market maker or broker-dealer. And then it changed the piggybacking and the ongoing obligation to say that it wasn't enough to review it once it had to be reviewed annually, and that disclosure had to continue to be made available. Otherwise, those companies would no longer be eligible for public quotation. What was interesting about all of it is that what it in essence did was it codified what we had done dating back to 2007 with our OTCQX and OTCQB companies. Basically, we were requiring those companies to continue annual disclosure. We were taking in that disclosure. We were posting it electronically and making it available to market makers, investors, broker-dealers, so there was timely and adequate disclosure. And what the SEC basically said is if that was working the way it was working, we'll kind of use that as the basis for how we think this should operate on a go-forward basis. Now underlying all of this, of course, was it was really around investor protection -- retail investor protection primarily, making sure that people that were buying and selling these securities that there was adequate information available for them to be able to assess the suitability. So 1 year ago yesterday, the rule was implemented. And if we go to the next slide, you can see kind of what that did to the markets generally. So we started 12,000 securities that were tiered our OTCQX, OTCQB, you'll see that top box there, Pink Current, Pink Limited, Pink No Information. That was really one of the focus points of the SEC was targeting those companies that were quoted, where there was no information. And then you'll see an Expert Market, those were securities where there was no public quote, but where qualified [indiscernible] or credited investors could trade those securities. If you look at the bottom box, you'll kind of see 1 year on. What has occurred in the market is you'll see a significant increase again of QX and QB securities. Again, because being on QX and QB, almost by default, qualifies you for that ongoing quotation obligation. You're making your information available. But interestingly enough, you'll see the entire Pink No Information tier just kind of goes away. So you're no longer eligible to be quoted on the OTC Markets without having some sort of disclosure. And if you don't have that disclosure, if you look to the bottom, you'll see Expert Market has grown to over 3,000 securities, that's where you'll end up. So you can still be traded. There are still accredited investors and qualified broker-dealers that can trade the security, but it's just not eligible for a public quote. So you wouldn't see a public quote on our website or if you went to Yahoo! Finance or things like that. So on the right, you'll see the QX securities increased by 9%, QB 14%. But more importantly, the cleanup of the tiers resulted in the downgrade of over 3,000 securities that weren't making their information publicly available. And that's where we sit now is companies can go in and out of these tiers based on making sure that their disclosure is timely and adequate and in many cases that we're the ones that are receiving that from the issuer and making sure that they're ingested and then posted out publicly for investors to see. I'll stop there, Bob.

Thank you, Jason. So just to reinforce the company's on OTCQX and OTCQB increased. Their obligations already were there. They were already doing what needed to be done with 2-11 reform.

Correct. The rule kind of codified what we have been doing already. And so for companies that woke up out of post this rule change and found themselves in the Pink Limited tier or potentially in the Expert or even in the Current tier because Current -- what causes the company to be Current is different than it used to be. It's now disclosure based versus just quotation based. What we saw was a lot of companies saying, "All right, well, I want to best foot forward, right, from a corporate governance perspective. I want to make sure I'm following all of the U.S. securities laws as it relates to the public quotation of my security. So best practice is, I'll just join the market." And so that's where we ended up.

Got it. Thanks. Let's go to the next slide. And we'll go to Rory Knight, Chairman of Oxford Metrica. And Rory talked -- please talk to us about the study that you did and your observations of the impact on the different tiers of the OTC Market?

Yes. Thank you, Bob, and good afternoon, everyone from Oxford. The introduction of the rule a year ago amounts to an endorsement of the hierarchy of tiers that OTC Markets Group has developed over several years to better serve U.S. investors and markets. And as Jason alluded to, the rule is an effect of codification of the structure that has strengthened markets. And the response, Bob, has been unequivocally positive, as you'll see in some of the summary results on the slide. And since the change, the relative value gap between the OTCQX, QB on one hand and the Pink tiers on the other has expanded by [ 15.7% ] in a volatile market. Now let me be clear, we are not looking at samples here. We're looking at the total populations. And let me also underline the fact that these are relative measures. We have adjusted for market movements. This has been a tough period for markets as a whole. So what we're looking for here is relative resilience, if you will. And that's what we've got in this particular metric. The main takeaway is that the -- those that were on the QX and QB tiers versus the Pink tiers, the gap is getting bigger, which reflects the value that the market puts on the better information. So that is the good news about that. But I think the real test is on the slide on the right-hand side of your screen. This is the litmus test. This is where we want to evaluate what the market is messaging, and it is clear. Those firms that switched up -- those firms that switched from the Pink tiers to the QX, QB enjoyed a massive increase in, again, relative value. Be clear some of these companies lost value in the down market, but they didn't lose as much as you would have thought. That is the key issue. And what we've got here is the total population of those switches. And that really, I think, is the major message that was this going to be a valuable idea, as Jason indicated, companies switched up, the market codified it and said, "You can go down or you can go up." Those that went up had a greater value resilience. Now this benefit is observable in volumes as well. We checked out what happens to market volumes. Now there has been a lot of trading during this period, and all [ boats ] were lifted by that. However, the QX, QB tier were 3x more in volume terms than the others, which suggest a greater liquidity creeping in, which again reinforces the results that we saw on the value side of things.

Thank you, Rory. That's very interesting. Also just tell us a bit about your firm, about Oxford Metrica.

Yes. Thank you, Bob. I'm glad you asked me that, actually. It's -- well, Oxford Metrica is a -- I was previously dean of the business school [indiscernible] business college. And we spun out this research firm called Oxford Metrica, and we do evidence-based research across many different subjects related to finance. So we've been doing that for just over 20 years now. So this is an area that we really enjoy working in.

Very good. Thank you. Thank you for your observations. We'll go to the next slide. OTC Markets 2-11 process for domestic companies, Joe Oltmanns, Senior Vice President of OTC Markets, Domestic. Joe, if you could fill us in on the changes there and how it's impacted domestic companies.

Sure. Good morning, everyone. Thank you, Bob, and thank you, Rory, for walking us through the data before. From the U.S. perspective, domestic perspective, I think there are 2 takeaways from the rule change. And Jason mentioned earlier, one is it cleaned up the Pink market. It brought a lot of transparency to Pink companies and those that chose to not comply with the rule we moved them to the export market. But secondly, and more importantly, it improved the capital formation process for small-cap companies. Companies are now able to complete a direct listing or registered IPO on to OTCQB or OTCQX, the same way would on NASDAQ or NYSE. Under the old regime, it was difficult to control the timing of an offering on the OTC. In order to go public, a market maker had to file a Form 211 with FINRA, which made it very challenging for the underwriter, the bankers and lawyers involved to align themselves with FINRA. And so under the new regime, we're now able to control the timing here internally. And so we performed the 211 review in parallel with the OTCQX or OTCQB application. And there's only a need to engage a broker-dealer or market maker separately to file the 211 with FINRA, which has been great news. The rule as obviously been in effect for over a year now. It's not brand new to us. We've onboarded roughly 2 dozen companies onto our market to get this process. The list of companies that have joined includes community banks, such as FirstSun Bank out of Colorado, Crypto Trust, such as Grayscale. And then some companies that have done prior private placements and then chose to access liquidity on our market thereafter. Given the IPO environment that we're in, I expect a lot more direct listings in our Q in the future. So if you are a domestic issuer considering going public, via an IPO, a fully registered deal or direct listing. Feel free to reach out. We'd love to learn more. Does that help Bob as a summary? Do you want me to expand more on anything?

No, Joe, I think that's perfect. Thank you so much. We'll shift gears now to the next slide and talk about the -- for international companies, the impact of 2-11 reform, and we'll go to Chris King, Senior Vice President, OTC Markets, International. Chris, please give us your observations as well.

Yes. Thanks, Bob. So I think as we look to explain the impact of the rule change for international companies, it's important to understand another SEC rule, which is the one that you can see on the slide there. So SEC Rule 12g3-2(b) is really the mechanism or the exemption through which thousands of companies listed outside the U.S., so they have their own domestic stock exchange listing, but they can be publicly quoted and traded in U.S. dollars and U.S. market hours without having to take on the additional burden and duplicative reporting of SEC filings, Sarbanes-Oxley. And so if you are a foreign private issuer listed on a qualified foreign exchange and you produce your disclosure in English, this is really the model through which thousands of companies, like Heineken and Roche and Hugo Boss and Adidas, cross trade into the U.S. on a daily basis. So it's an important role. And if you think about prior to the rule change for 15c2-11, as Jason mentioned, the way in which those companies would originally have been set up on our markets, whichever they tier, was through a filing of a 211 through FINRA, but that's just the initial review. And so I think really something to focus on here for the international side of our business is that what the SEC was rightly concerned with is the fact that there was no ongoing due diligence around ensuring that companies continue to be compliant with this reporting exemption. So for companies on exchanges that do require English reporting, we had to solve this issue. And so we did this in a number of ways. So for companies that are already on a stock exchange, where English language for reporting purposes is a requirement, we are able to apply a current reporting status to those companies, assuming that they continue to meet local exchange standards. But obviously, the vast majority of international companies were actually listed on stock exchanges where English is not a filing requirement. And so we're unable to do an individual ongoing review of all of these companies on a regular basis without engagement from the company. So we created a filing service. It's called our disclosure and new service where international companies are now able to use their existing disclosure required from the home market. But as long as they're filing the information through our system, we're able to review that and make sure that they continue to comply with SEC Rule 12g3-2(b), and be considered current for reporting purposes. Those companies that do not file the -- they're not listed on an exchange where English language is required and they do not file their disclosure through our filing system, we relegated those companies from a reporting perspective to limited information. Certainly, we're not saying no, these securities cannot be traded, but they may or may not meet the exemption. So without a review, those companies remain limited for reporting purposes. It was mentioned before that companies that are trading on our QX and QB markets to really meet the new rule set. They're already posting the home market disclosure on to our system. So those are reviewed by us and verified by OTC Markets Group and they are labeled on our securities file as meeting the 12g3-2(b) exemption for reporting. So I think in summary, Bob, I'd just say that as was discussed earlier, right, investors and brokers internalize the rule change, modified their behavior. And so naturally, we've seen companies on our premium markets certainly outperform companies that are on our lower tiers of our market.

Right. And we've seen an increase in companies joining the premier tiers as well as was pointed out. Thank you, Chris. We'll go to the next slide. And I'll go back to Jason Paltrowitz, EVP of the group. Jason, for your observations before we go into the Q&A part of our presentation.

Thanks, Bob, and thanks to everybody. I guess the final point that comes through as we look 1 year on, what are we saying? What is the data that Rory's presented, Oxford Metrica has presented? What are the things that we're seeing in the market? What it really is, is what the SEC had intended. And that's what the data shows, is that the market is reacting, investors are reacting by moving their investments or by focusing on securities where the most information is available. And so when we say things like QX and QB have seen that value growth, whether it's tightening of spreads or increased volume or value, what that really is, is investors that when they're looking to invest in companies are looking for those companies that are providing the greatest amount of disclosure and transparency. And so the 1 year on reaction is just that the investors are voting with their dollars, if you will, that the more transparent, the more timely a company is in its disclosure, the more open and transparent they are, the more likely they are to see investment, whether that's from retail, small institutions or the like. So the market has reacted positively. I think we're very proud here as to the role we've played in that, not just providing better information disclosure and transparency to investors, but being able to get rid of bad actors in the market. And I think the movement of securities that were dark or distressed. We're moving the public quotation of those securities, I think, has enhanced the market more broadly. And so you do see that in these value benefits and liquidity enhancement numbers that we show here. And so this continues to be an evolving process. We continue to work with the SEC and FINRA to make sure we're doing all the things that we need to do to make this market as vibrant and investable as we can. But the indications from 1 year on are certainly that the SEC was right to act. They were right to update what was an old rule to bring it into the 21st century and to make sure that there were investor protections in the market in line with what you would find on the national exchanges. And so I'll kind of end it there, Bob. I think we got a bunch of questions in the queue.

Yes. That's right. Thank you, Jason. Yes, we'll go to the next slide, and we'll go into the Q&A part of the webinar. So I think this first question is really geared toward Rory Knight, Chairman of Oxford Metrica. As companies were downgraded from OTC Pink Current to OTC Pink Limited, what happened to the companies that were downgraded statistically? And then there's a follow-up question about the 16.7% separately value that you talk about in your slides as well.

Thank you. Thank you for the question, Bob. The -- yes, we have looked at the -- what happens to the switches from Pink Current of Pink Limited and the result is a loss, an increase in the value gap, negative of 2.7%. So it's quite clearly a signal, as Jason was saying, that investors are flocking away from that towards information and away from companies, which have a reduced amount of information out there. So that seems to be confirmed. The 16.7%, that's a market adjusted rate. In other words, it's the difference between where the stock would have been given where the market had gone down, given its risk profile versus where it was. In other words, things didn't get as bad as they should have, given what the market had done. So it's the standard risk-adjusted return. Thank you, Bob.

Got it. Thank you, Rory. That's helpful. Okay. So let's go to the next question. Give me a minute here. If you uplift to OTCQB or OTCQX, does that remove the need to have a 15c2-11 filed?

So yes, Bob, I'll take that one. So it depends. The answer is, if you are a private company, meaning don't have a symbol or trading symbol yet, and you want to apply for OTCQB or OTCQX, we can perform what's called the initial review, which has replaced the old 211 review, and you do not need to engage a market maker separately to file a 211. So I hope that answers that question. Now a Pink company already with a symbol, trading on Pink and looking to upgrade to OTCQB or OTCQX. No, you do not need to obtain a market maker to file 15c2-11, nor do we do anything here internally in that regard either.

Thank you, Joe. There is a...

I'm just going to add to that, bob. So to Joe's first point, if you're a private company that needs to have the old 211 process, right? You want to be publicly quoted. That initial review process is something that we've incorporated as part of the OTCQX and QB onboarding. We can do that initial review. However, what's different in the new rule is there is an initial requirement. And remember what I mentioned, there's an ongoing requirement. And part of the ongoing requirement, not just the filing of your financials and disclosure with us on an ongoing basis, but there is the requirement that a market maker is quoting the security. So while we can do the 211 review and make the company public "eligible," those are the term, right? So you're eligible to have a public quote. You still need to ensure that there is a market maker quoting your security because if the market maker isn't quoting the security, then you fall out of compliance as well, and so we help with that as part of the process. But there's 2 things that need to be done there, right? There's the review are you publicly quote eligible, and then there is the -- a market maker actually needs to quote the security. And so we can work on both of those fronts.

Thank you, Jason. We have a related question from a company that presently trades in OTC Pink, they'd like to move to OTCQB. They want to know what are the requirements, practically how difficult is the process, and what are the pitfalls in making the transition?

Joe?

Yes. So I assume it's a domestic issuer asking the question, so I'll give the domestic response. There are a few basic requirements joining OTCQB, one being a $0.01 bid price, the second being current with your disclosure and also being our distribution requirements. I don't want to go too into the weeds with all the requirements around OTCQB. But essentially, the process takes roughly around 6 to 8 weeks to complete. We go through a full background check, due diligence check on our end. In terms of pitfalls, there are no pitfalls of joining a better market. There's a cost and time to going into joining OTCQB. But like I said, the process does take roughly 8 weeks to complete. It's much like what you would experience in applying for a listing on NASDAQ or NYSE.

Thank you, Joe. Okay. Here's a question, what is a company that has fallen into the Expert Market need to do to get back quoted on OTC Market tier? And talk a bit about also what is the Expert Market?

So again, we get into -- this is the process of that initial review. So a company that is in the Expert Market is there most likely because they were not making their information publicly available anywhere, right? And so per the rule, we're not eligible for the public quotation of their securities. And that's really what the SEC was doing here. The public quotation of a security means that almost anybody can buy and sell practically speaking, and you can see that public quote. A company that moved into Expert can still be traded, but there's no public quote, which means that it's really amongst a qualified universe of investor, a broker-dealer, an accredited investor, where those shares can be traded without the general public, retail being able to see that quote and act on that quote. Again, not being allowed to do that because there's no publicly available information to -- for an investor to decide whether this security is investable or not. So to get out of Expert Market, it is that 211 process. Now again, the rule doesn't say that OTC Markets owns this process. That company can go find a market maker or a broker-dealer that does that 211 process on their own or that company can come through OTC Markets if they meet the OTCQB or QX standard and can join that market. I think Joe mentioned we have a service for Pink companies that want to make their disclosure available, the DNS service. It would require a 211 review and the ongoing requirements to meet the new rule.

Thank you, Jason. We have a question which is in reference to, can you differentiate a Pink Current issuer versus a Pink Limited issuer? What's available to brokers, investors on the former versus the latter, as both allow publication of proprietary quotes?

So I can take that from the international side, if it would be helpful. So as we were talking about earlier, right, the impact of this reform required OTC Markets Group as the market operator to come up with solutions and ways of supporting a variety of different types of companies, right? And so on the international side, being Current -- being considered Current in your reporting, whichever tier of the market you trade on, is important. It's important in terms of information flow. It's important in terms of how broker-dealers treat you. They all need to manage their risk. Investors need to be connected and engaged with the issuer. And so most of the companies that you see on the international side who have a Pink Limited label simply means that those companies have not been reviewed to ensure that even though they may be Current on their home exchange listing, no one has done the due diligence to ensure that they meet the 12g3-2(b) exemption for reporting, which is critical for, of course, ongoing trading within the U.S. in compliance with that rule. So the key difference here, I think, is that investors are, as Jason was saying, right, investors are attracted to transparency and better corporate governance. And so a lot of the time, if you're doing your research and you look even on the OTC Market side, if you look at companies that are great companies listed in Germany or France or in Israel, as an example, you see Pink Limited. It's basically a warning to the market participant or the investor that you need to do additional due diligence, additional research, and there's thousands of securities that now fall into this category. So I think that's probably on the international side, the significant difference between having been labeled as Pink Current versus Limited. And then obviously look for that 12g3-2(b) certification as that's an important feature as well.

Yes. On both markets, that difference is really around the timeliness, verification and readily availableness of the disclosure. So in the U.S. world, if you're late in your disclosure, you're not timely in meeting your requirements, you would end up in the Pink Limited tier. In the international world arena, if we've been unable to verify to Chris' point, you're -- because you're not making -- and we've created mechanisms to kind of try to streamline this, and Chris alluded to it. If you're on a qualified foreign exchange that requires English, it's relatively easy for us to feed that stuff through and verify it. If you're not, it's a little harder. And so we don't have the capability to do that for 10,000 international securities. So if we're unable to make that verification, then perhaps you'd be in Limited. There are other criteria around this rule around exemptions for large companies, average daily trading volume and other things. So there are a number of things that feed into Current and Limited. What's interesting is now that it's disclosure based, what you find now is bankrupt companies will now be Current, whereas historically bankrupt companies would be either Pink Limited or Pink No Information. And so because it's disclosure based, you can be bankrupt and Current because you're making your bankruptcy disclosure available in a timely fashion. So to the last part of that point, that is part of the reason that you see those valuation gaps between Pink Limited and Pink Current. It's changed what it means to be a Pink Current and a Pink Limited company. And so the friction for broker-dealers is the readily -- the ability for investors to invest in those securities has changed given that the types of securities in those buckets have changed as well.

Thank you, Jason. I think we have time for a couple more questions. This question is in reference to market makers. Can someone explain how OTCQX or OTC Markets fits into the space of market makers? Is it an internal market maker for OTC Link, OTC Markets? And how and when does it place its quotes?

We are not a market maker. So the market makers that quote the securities on our market are market-making firms that you've heard of Virtu, Citadel, Jane Street. They access our trading platform for subscribers to the OTC Link trading platform, but we do not make markets, we do not put up proprietary quotes. We simply run the technology that facilitates the messaging by broker-dealers, market makers, messaging and quoting of the securities that are on our market.

Thank you, Jason. Here's another related question about market makers. If an issue of security becomes unquoted by a market maker, what is a remedy period before they are moved into the Pink or a gray market? Is it 4 days? Or has that changed with the rule?

Somebody else want to take that, Joe?

So the question is if you're treating on Pink and you moved to -- I'm sorry, to Expert, you said, Bob...

Yes, if you become unquoted by a market maker, therefore, moved into the Pink or gray, is there a great period? And then how do you get back on to the market?

So to get off of Expert and back on to Pink QB or OTCQX, there are 2 options, but both require the initial review, whether it's us doing it here internally or you would work with an outside broker-dealer on a 211 with FINRA. That process, though, will take a few weeks to kind of get through. So companies that do move on to Expert to get back on to, again, Pink QB or QX, it's not going to be an overnight process, to be clear, it's going to take a few weeks. But normally, companies that fall into Expert, usually fall in due to being delinquent with their filings. And so that alone, I think, will take some time just to kind of catch up. So it hasn't been an issue for any company in kind of moving back up off Expert. It's really disclosure-driven. And so it usually kind of takes place or solves itself once the company becomes current again with its filings.

Very good. Thank you, Joe. We have 1 more question. What are common questions we get from QX and QB companies since the 2-11 reform?

What are common questions we get from QX and QB companies since the 2-11 reform?

Yes.

I don't know that there is a set of common questions just because those companies are kind of meeting the requirements. Certainly, Bob, you run the group, so you know better than I do. There's a consistent or constant ongoing dialogue with all of our issuers around what the new rule change means, its impact generally on the market. We certainly have conversations in the Oxford Metrica study, something that we've discussed with all of our issuers about how it's positively impacting not just their U.S. trading, but their home market trading. We have conversations around U.S. securities laws, whether those are state Blue Sky Laws or this new regulation and how it impacts them. Really, the question, if I were to ask, it would be more around Pink companies and what are we talking to them about. And you'll find that companies that are Pink Current 1 day wake up the next day and they're Pink Limited. Again, a lot of that is because there's different criteria around trading volume, value timeliness of local market disclosure. And so at any given moment, a company that's on Current could wake up and be Limited, And they don't understand why that's happened, and they usually call us because investors are calling them. Their investors are calling them and saying, there's this friction now, and I can't buy. In fact, we had an NYSED list last week that ended up in Limited and now their phone is ringing because investors that historically could have invested that are now Limited, there are problems there. And so that's where most of those conversations are, what is the new Pink Limited versus the old? How is Pink Current different? And what are the impacts all of these new rules have on again, primarily retail, family office, small investors ability to trade those securities.

Right. Thank you, Jason. And I would just reinforce our group. We obviously work with all the OTCQX and OTCQB companies. And you're right. I mean we were just -- we've always just been very clear to state that they've already been doing the proper disclosure, and they -- we were pleased to forward the Oxford Metrica results, which showed the value of being on the premier tier. So with that, I'm going to wrap it up, and I want to, first of all, thank our guest speakers and, of course, thank all of you in the audience for listening in on this educational webinar. We will -- again, we will be sending out this webinar, a copy of it to all that have registered, and it will also be available on the OTC Market's website. So again, thanks to all of you, and we appreciate it.

Thanks, Bob.

Thanks, Bob.

Thank you, Bob.

Thank you.

Bye. Thank you.