Reveille Capital × KMB Insights

The path to a US listing runs through readiness.

Every OTC uplist decomposes into the same seven steps. The audit everyone fixates on is step four, and what it costs is mostly decided by how well steps one through three were done.

01 // The seven steps

One sequence, every company

01

Listing path & reporting requirementsAdvisory

Classify the company: thirty minutes that decides everything. US-incorporated means OTCQB Alternative Reporting, US GAAP consolidated financials, and a PCAOB-registered audit. Tier, eligibility rules, and disclosure obligations are fixed here.

02

Discovery & data aggregationAdvisory + Company

Entity map, data room, document-request process. This is where the required disclosures and the scope of work get discovered: entity structure, material contracts, related-party arrangements, litigation and contingencies, compliance posture. Every surprise found here is a decline or a blown fee avoided later.

03

Uplift proceduresAdvisory

Companies have books; they rarely have GAAP financial statements. This step formalizes them: technical accounting assessments, disclosure requirements, drafting of agreements and policies, and full statements including cash flows and equity, all built on an auditable support trail.

04

AuditCompany retains · Advisory runs the PMO

Every RFP starts with the completed reporting package: firms get something finished to quote instead of pricing uncertainty. The advisory team runs the RFP, then project-manages fieldwork end to end as management's experts.

05

Listing & disclosure packageAdvisory drafts

The disclosure document, MD&A, issuance history, and material-contract exhibits, drafted from the consolidated financials.

06

Market mechanics & governanceCompany + counsel

Transfer agent, shareholder count and float, independent directors, audit committee, D&O. The cheapest items on the plan with the longest lead times; they start on day one, in parallel.

07

Admission & ongoing reportingCompany, on the machine built in step 5

Application and background checks, then the recurring cadence: annual report in 90 days, quarterlies in 45, current reports in 4 business days.

02 // Sequencing rules

Three rules protect the budget

// RULE 1

Consolidated draft before the audit RFP

Going to market without one is how first-year audits run 3 to 4 times over the quote.

// RULE 2

Legal opinions before audit dollars

Unresolved legal questions collect hard declines from audit-firm risk committees: ownership and control confirmations, litigation and contingencies, potential non-compliance. Resolve them on paper first, before anyone prices them as risk.

// RULE 3

Governance and mechanics start immediately

Director searches and holding periods are calendar-gated, not effort-gated. Waiting costs months, not money.

03 // Audit economics

The fee is built on complexity; readiness contains it

Microcap OTC audits run $45K to $250K+ per year, priced on entity count, risk, and hours, not revenue. One driver is controllable, and it is the largest.

// What a company can't control

Structural drivers

  • Multi-entity consolidation and eliminations
  • Foreign operations, currencies, and physical inventory locations
  • Multiple revenue streams and complex revenue: percentage of completion, agent vs. principal
  • Complex arrangements and transactions: M&A, debt and equity financings, private instruments
  • Ownership and control confirmations
  • First-year audit ramp-up: a 20 to 40 percent premium, always
// What readiness buys

The controllable driver

  • Finished consolidated financials: firms quote a package, not uncertainty
  • Technical memos written before fieldwork starts
  • Structure questions pre-answered with counsel opinions
  • Organized support: the document exists before the auditor asks
  • Management's-experts model lowers the first-year risk assessment
04 // Where every engagement starts

The readiness assessment: fixed scope, 2 to 4 weeks

From the initial discovery documents and management calls, the first deliverable set maps the whole journey:

D-1

Classification memo

Which reporting path, why, and the GAAP/audit consequences.

D-2

Eligibility gap table

Shareholder count, float, governance, control-person transparency, good standing, each scored with an owner and lead time.

D-3

Entity & consolidation scope

Every entity: jurisdiction, ownership, accounting basis, books condition, consolidation call.

D-4

Triaged project plan

The seven steps as workstreams, each Now, Gated, Client-side, or Outside-specialist.

D-5

Cost stack

Who does what, who pays: advisory, auditor, counsel, transfer agent, exchange fees.

D-6

Live roadmap

A status page tracking the engagement against this framework, updated as phases progress.

Basis: OTCQB Rules v6 (Apr 2026), OTCQX/OTCQB Disclosure Guidelines v13.1, SEC Rule 15c2-11, and disclosed audit-fee comparables from EDGAR. Full methodology maintained by KMB Insights.