"OTC stock compensation is increasingly at issue in retirement plans because of both a large retiring generation and the prevalence of equity awards at start-ups. Criminal enforcement of insider trading, market manipulation, and other securities fraud remains high. Both the DOJ and the DOL are encouraging voluntary self-disclosure and self-correction of non-compliance in common areas of fiduciary risk, such as transactions involving parties in interest, illiquid assets, and potentially improper valuations. Plaintiffs' lawyers are increasingly targeting OTC issuers/employers and their retirement plans to contest potential liquidity, valuation, or transfer problems involving OTC stocks."  MORE >>