I’m writing as a long-time trader in the OTC markets to share my honest concerns about how Rule 15c2-11 has impacted retail investors like myself.
This rule may have been created with good intentions — to protect investors and clean up bad actors — but the way it’s been enforced has done real damage to people who’ve spent years trading these markets responsibly.
Since the rule was expanded, thousands of tickers have become untradeable for no clear reason. Many weren’t scams or shell companies — some were just inactive or foreign issuers. But instead of giving investors a chance to evaluate these risks for themselves, the rule took away access completely. Positions are now stuck, with no way to exit. That’s not protection — it’s punishment.
The “Expert Market” doesn’t help. It just locks out everyday traders and hands access to institutions. That’s not a level playing field — it’s the opposite. People like me who’ve spent years building knowledge in the OTC space are now being treated like we don’t know what we’re doing. That’s frustrating and unfair.
What’s worse is there’s no real path back. Even if a company wants to become current, it’s a slow and unclear process. Meanwhile, real money is tied up, and retail traders are left holding bags we can’t even sell.
I’m not asking for free rein or zero rules. But there needs to be a more balanced approach. Let broker-dealers quote based on available public info. Give companies a clear way to get relisted. Give investors some say in what risks we’re allowed to take.
Right now, Rule 15c2-11 is hurting the very people it was meant to protect. I hope FINRA will take a serious look at these unintended consequences and push for changes that restore access and fairness to the OTC markets.
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Kevin Comment On Regulatory Notice 25-06
To Whom It May Concern at FINRA,
I’m writing as a long-time trader in the OTC markets to share my honest concerns about how Rule 15c2-11 has impacted retail investors like myself.
This rule may have been created with good intentions — to protect investors and clean up bad actors — but the way it’s been enforced has done real damage to people who’ve spent years trading these markets responsibly.
Since the rule was expanded, thousands of tickers have become untradeable for no clear reason. Many weren’t scams or shell companies — some were just inactive or foreign issuers. But instead of giving investors a chance to evaluate these risks for themselves, the rule took away access completely. Positions are now stuck, with no way to exit. That’s not protection — it’s punishment.
The “Expert Market” doesn’t help. It just locks out everyday traders and hands access to institutions. That’s not a level playing field — it’s the opposite. People like me who’ve spent years building knowledge in the OTC space are now being treated like we don’t know what we’re doing. That’s frustrating and unfair.
What’s worse is there’s no real path back. Even if a company wants to become current, it’s a slow and unclear process. Meanwhile, real money is tied up, and retail traders are left holding bags we can’t even sell.
I’m not asking for free rein or zero rules. But there needs to be a more balanced approach. Let broker-dealers quote based on available public info. Give companies a clear way to get relisted. Give investors some say in what risks we’re allowed to take.
Right now, Rule 15c2-11 is hurting the very people it was meant to protect. I hope FINRA will take a serious look at these unintended consequences and push for changes that restore access and fairness to the OTC markets.
Thank you for your time.
-Kevin