When Disclosure Pays: Evidence from the Over-The-Counter Markets

Abstract

A familiar concern among policymakers is the shrinking number of U.S. publicly traded companies. For instance, SEC Commissioner Hester Peirce recently highlighted that the number of listed firms has fallen from approximately 8,000 in 1996 to around 4,200 in mid-2022. Increasing the supply of public companies has been a bipartisan policy objective.

Yet this debate often overlooks thousands of firms traded outside national exchanges on the over-the-counter (OTC) market. While not “listed” in the traditional sense, many of these firms’ securities are publicly traded via broker-dealers and interdealer quotation systems (IDQS). OTC Markets Group, for example, enables retail investors to buy and sell the stock of nearly 5,000 U.S. issuers.

Details

Author(s):
Publish Date:
September 25, 2025
Publication Title:
Harvard Law School Forum on Corporate Governance
Format:
Op-Ed or Opinion Piece
Citation(s):
  • Robert Bartlett & Colleen Honigsberg, When Disclosure Pays: Evidence from the Over-The-Counter Markets, Harvard Law School Forum on Corporate Governance, Sep. 25, 2025.

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