The Day the Phones Stopped Being Answered

On October 19, 1987, the Dow Jones Industrial Average fell 22.6% in a single session, closing at 1,738.74. Black Monday was not just a brutal day for stocks. It exposed how quickly market access can break down when selling turns chaotic, and it helped push the market toward safeguards like automated execution and circuit breakers.

The lesson still holds: a market is only as strong as the access it protects when everyone wants out at once. Black Monday was a crash, but it was also a reset.

Texas Capital Bancshares announced on September 14 that it will move its primary listing from Nasdaq to the Texas Stock Exchange, the first transfer of an existing public company's listing to the new exchange. We said in September that October was the month to watch for a corporate listing. Here are the dates:

The move lands almost exactly one year after the SEC approved TXSE's registration on September 30, 2025. Why it matters for smaller companies: a third listing venue means competition on listing fees and standards. The companies to watch are those that could qualify for a national exchange but have stayed on OTCQX or OTCQB because of cost. Announcement →

The Celsius Holdings Story

Celsius Holdings began as a relatively small functional beverage company and traded on the OTC market before moving to the Nasdaq Capital Market in 2017. What happened afterward shows how the public markets can become part of a much larger long-term growth strategy.

The Celsius story illustrates an important point for emerging companies: an OTC listing does not have to be the end of the road. It can be one stage in a company's public-market journey.

Building a successful public company requires much more than obtaining a trading symbol. It requires a viable business, access to capital, effective execution, strong professional support, and a long-term strategy. Celsius provides a real-world example of where that journey can potentially lead.

The Exchange works with companies at virtually every stage of that journey, from Rule 15c2-11 and Form 211, through OTCQB and OTCQX, and toward Nasdaq or NYSE uplisting when the company is ready. For companies at the start of that path, we prepare the complete Form 211 package with you, document by document, working alongside your legal and accounting team.

Our network also extends beyond uplistings. We regularly hear from parties on both sides of public-company transactions, including principals considering the acquisition or sale of an existing public company and private companies evaluating a path into the U.S. public markets.

The OTCQB Bid-Price Requirement

Under the current OTCQB Rules, new applicants must meet a minimum bid price of $0.05 per share as of the close of business on each of the 30 consecutive calendar days immediately preceding admission. The continued-qualification standard remains $0.01 per share. This requirement became effective April 6, 2026, and it remains in the OTCQB Rules in force today, Version 6.1 dated September 17, 2026. In other words, it is not a new rule, and any checklist still showing $0.01 for admission has been out of date for about six months. For the full text, see the current OTCQB Rules.

Moving Up the Market

In August, 28 companies joined OTC Markets' two premium tiers, with 10 joining OTCQX and 18 joining OTCQB. The activity is another reminder that the public-market ladder remains active, with companies continuing to seek greater visibility and access through higher market tiers.

For companies already trading publicly, moving to a higher tier can be part of a broader strategy: improving visibility, strengthening credibility, expanding access to investors, and, for some companies, positioning for a national exchange.

OTC Markets Extends Its Reach Into Asia

OTC Markets Group announced a market data licensing agreement with CITIC Securities Brokerage (HK), part of CITIC Securities' international arm. CITIC will distribute OTC Link pricing to its Hong Kong clients, with 15-minute delayed Level 1 quotes as the baseline and real-time data for premium subscribers. For U.S. OTC issuers, it is one more window into an overseas retail investor base.

The demand is already there. Trading in Asia Pacific securities on OTC Markets reached $19.49 billion in the second quarter, up 34.1 percent from a year earlier.

The company is also building on the digital asset side. In July it announced a proposed strategic alliance with BitGo Bank & Trust and an integration with Elysium's MatchHub platform, aimed at connecting digital asset trading with qualified custody for blockchain-native securities. Second quarter gross revenues were $34.8 million, up 14 percent year over year. Announcement →

The CLARITY Act Falls Short in the Senate

Last month we reported that the CLARITY Act finally had a date. On that date, it ran out of votes. The September 15 cloture vote on the motion to proceed to H.R. 3633, the Digital Asset Market Clarity Act, needed 60 votes to succeed and received 49.

It is not formally dead. A motion to reconsider was entered, which keeps the procedural path open. The Senate's 2026 target adjournment is December 18, so the remaining window for further action this year is narrow. For public companies, the practical question is not what Congress does next. It is what governs in the meantime.

Regulators have been building a framework on their own all year. In January, SEC Chairman Paul Atkins said Project Crypto would proceed as a joint SEC and CFTC initiative. In March, the SEC issued an interpretive release, joined by the CFTC, establishing a five-category taxonomy for crypto assets and drawing the line between securities and non-security commodities. The agencies have separately advanced coordination through their harmonization work and a memorandum of understanding.

In August the SEC proposed Regulation Crypto Assets, a tailored offering framework for certain investment contracts involving crypto assets. The comment period closes October 20. With CLARITY stalled, this is the track public companies need to watch, and it means the rules can shift with agency leadership rather than being fixed in statute.

Companies that hold digital assets, issue tokens or are exploring tokenized securities should keep their disclosures about those activities current as the framework takes shape.

Q3 10-Qs Are Due. Semiannual Reporting Is Still a Proposal

For a September 30 quarter end, the 45-day deadline for non-accelerated filers lands on Saturday, November 14, so it moves to Monday. Remember that EDGAR is closed Wednesday, November 11.

In May the SEC proposed letting companies elect semiannual reporting on a new Form 10-S instead of filing three 10-Qs a year. The comment period closed July 6. No final rule has been adopted, so quarterly reporting remains the requirement and Q3 10-Qs are due on the normal schedule. sec.gov →

If the rule is adopted, the savings for smaller companies could be real: one interim report instead of three, with less XBRL tagging, review and audit work. OTC companies should weigh the other side too. Current public information drives Rule 15c2-11 quotation eligibility, OTCQB and OTCQX standards, and investor confidence. A company that wants to stay quoted and credible may find that filing less often does not mean disclosing less.

The SEC and EDGAR are closed, and EDGAR will not accept filings that day. Anything due on the 12th moves to Tuesday, October 13, and the holiday does not count toward business-day deadlines such as the four-day 8-K window. View the EDGAR calendar →