Into the Markets We Go
The Exchanges and Their Guessing Game
By DWN-team · Nov 2, 2026 Views: 202
By Eddie Tobler, Managing General Partner at West Coast Stock Transfer Corp
Recently, the would be NYSE change to the $0.25 minimum trading price which would result in an immediate suspension of trading and commencing the delisting proceedings. This was approved on August 14, 2026; however, it will not take effect until July 1, 2027. This is in addition to the existing rule requiring a $1 minimum price threshold and a six-month curing process. Obviously, those issuers that trend toward the bottom of the range have to be expeditious with their corporate re-org events to try to resolve the problem (i.e., a reverse stock split).
In addition, we have the NASDAQ with its attempts to thin out the markets based on MVLS values. Between their 5M MVLS delisting rule change and their historical suspension ranges between the $1.00 notification and the dime suspension threshold, tons of companies are at risk here. Thankfully, these changes are on hold for now thanks to the hard work of Marc Indeglia and the Small Public Company Coalition. However, in the long term, this rule change request will be reviewed by the SEC, and some form of pronouncement will take place.
This is where we get into the guessing game of who’s going down to OTC Markets, who’s not going to be able to raise money, and who’s not going to be able to get shares deposited and keep up with the market liquidity they need. This is what makes entering the markets such a stressful and all consuming endeavor, those things that happen when something goes wrong.
How to calculate the SWAG.
Which leads us to trying to make some intelligent assumptions on what may happen, and how things could play out in the markets. For this we refer to the term below:
“Scientific wild-ass guess (SWAG) is an American English slang term meaning a rough estimate made by an expert in the field, based on experience and intuition.”
Herein lies the fact that this is just a guess, however I do have some experience and I tend to follow my gut. Over these past ten months the SEC has broadly expanded those things that they find acceptable as it relates to the activities of market participants. These are most well evidenced in their approach to crypto regulation and to the tokenization of equities.Earlier this year there was an explanatory note provided by the SEC that gave a loose framework as to their view of what constituted examples of Tokenized securities. In that release it is perhaps most relevant for us to look at the Issuer-Sponsored tokenized securities as the model that will hopefully find broad based support. Exhibits of other models are also included however they tend to be those which are less likely to be of benefit to the issuer or to the shareholder and therefore will hopefully be less likely to have any substantial adoption.
Which leads me to my SWAG at what this will mean to all of us going forward. Just last month days after the Senate failed to pass the Clarity act the SEC decided to take matters into their own hands. This pronouncement from the SEC facilitates the creation of trading venues for tokenized NMS stocks. This is important for a multitude of reasons but most significantly because in my opinion it allows for and accommodates the expansion of the capital markets.
As we all know when issuers exit the listed exchanges there is but one place for them to land at this point, OTC Markets. Therein they lose significant attributes of the exchanges. The ability to do an underwritten offering is severely constrained, their trading volume is impaired and the ability for small(er) shareholders to deposit their shares is severely limited (further exacerbating all of the other problems).
So why tokens? Because it’s a venue OUTSIDE the normal auspices of FINRA. It’s therefore my belief that the rapid acceleration of Tokenized securities is perhaps an attempt by the powers at be to make the process to the public markets less onerous, and the ability to stay there and viable less contentious. In the next few years we will most likely see many issuers adopt some form of tokenized model that gives investors access to the markets to sell what they may have invested in privately or other investors the ability to purchase securities therein. I had this epiphany a couple of weeks ago and I am really hopeful that this will make the markets more accessible and palatable for more issues.
So I guess Tokenize the world!?!?
References
https://en.wikipedia.org/wiki/Scientific_wild-ass_guess
https://www.sec.gov/files/rules/sro/nasdaq/2026/notice-intent-petition-spcc-072926.pdf
Disclosure: The views and opinions expressed in this article are those of the author and do not necessarily reflect the views of West Coat Stock Transfer Corp. or any of their respective affiliates. This article is provided for general informational and educational purposes only and does not constitute investment advice, a recommendation, an offer to sell, or a solicitation of an offer to buy any security, financial product, or investment strategy. The information presented is believed to be reliable but is not guaranteed as to its accuracy, completeness, or timeliness. Any forward-looking statements or opinions are subject to change without notice.
Author Bio: Eddie Tobler is an issuer and shareholder focused professional with over a decade of experience in Corporate Actions, governance and shareholder communications. Specializing in Community and Regional Banking with an emphasis on banks transitioning to the public markets, as well as those involved in M&A activity.