Your Regulation A+ shares can be freely tradable, subject to the specifics of your offering and shareholder status. That leads founders to ask the obvious follow-up: tradable where, exactly? If you're planning a future Nasdaq or NYSE listing, building a credible secondary market early gives investors a real exit path and sharpens price discovery. It also signals something to the market itself: that the business is already operating as a public company.
This article covers how growth-stage companies integrate with modern Alternative Trading Systems (ATS) to provide secondary liquidity ahead of a major exchange listing. It is not easy, not free, and not something you switch on in a weekend between product sprints.
We work with companies raising capital online, mainly through Regulation A+ and Reg D. We don't run secondary market trading ourselves, but we introduce companies to the right ATS providers and coordinate the full stack of specialists needed to make Listing work.
Why secondary liquidity matters in a Regulation A+ journey
People lump Regulation A+ in with crowdfunding. That's the wrong frame. It's an SEC-qualified, public-style capital raise that can support a real path to becoming a widely traded company.
Primary investing runs on an optimistic view of the future prospects for a company. Secondary liquidity adds something different: the comfort of an optional exit, even for investors who never use it. That comfort changes how people commit capital, and it can reduce friction later when a company moves toward an IPO or major exchange listing, because it shows an engaged shareholder base and a functioning market mechanism already exists.
None of that happens automatically. A secondary market does not create demand out of thin air. If a company stops marketing itself, the market goes quiet. That's not an ATS failure. That's a promotion and investor-relations failure.
"Freely tradable" doesn't mean "liquid"
Founders hear "freely tradable" and picture a button labeled LIQUIDITY. There isn't one.
Real liquidity requires an exchange, broker connectivity and trading operations, ongoing issuer communications, a steady flow of buyers and sellers, and clean compliance and transfer agent processes behind all of it. Skip any one piece and the rest doesn't matter. This is engineering work, not wishful thinking.
What an ATS actually is
An Alternative Trading System is a regulated venue, operated by a broker-dealer, that matches buyers and sellers outside a national exchange. It runs on rules and surveillance like a major exchange does, but the listing requirements are easier to meet, the listing fees are lower, and there is no shorting or naked shorting of your shares.
Don't expect extremely high valuations on an ATS. But your share price won't be destroyed by brokers putting naked shorts on your stock either. That is a worthwhile benefit for many early-stage public companies.
When an ATS makes sense
An ATS fits when you've completed (or are completing) a Regulation A+ raise, your shareholder base is large and active enough to support real trading, and you're building toward an uplisting from OTC to Nasdaq or NYSE.
The practical integration path
Companies activating secondary trading cleanly need to get four things right.
Reporting, disclosure, and investor communications need to function at a public-company standard. Regulation A+, particularly under Tier 2, comes with ongoing reporting obligations, and companies must live up to the SEC audit requirements and those of the ATS. Some ATS require more frequent management financials or audits than the SEC, some don't.
A strong transfer agent is non-negotiable. This is the unglamorous work of issuances, transfers, and keeping the shareholder ledger accurate at scale, and it's exactly the piece companies are tempted to skip.
Choosing the right ATS means matching the venue to your actual goals, not the most familiar name. The right fit depends on expected trading volume, shareholder demographics, communication cadence, and where you're headed long term, whether that's OTC, Nasdaq, or the NYSE. We help manage the attorneys, auditors, marketing agencies, transfer agents, and secondary venues so companies aren't stitching this together alone.
Onboarding and compliance workflow also need to be sorted out ahead of time: identity verification, broker-dealer onboarding where applicable, and making sure shares actually transfer cleanly. On broker-dealers specifically: in Regulation A+ raises, they're optional, and in most cases, we recommend avoiding them. They add cost, FINRA's pace can slow things down, and FINRA frequently restricts advertising in ways that make raising capital harder. The one place underwriters earn their keep is a NASDAQ or NYSE IPO in a strong market.
Marketing and investor outreach don't stop once the raise closes. Any platform implying you can skip meaningful ad spend in a crowdfunding-style raise is setting you up to fail. Issuers usually need to spend real money on ongoing promotion to reach investors efficiently, and a liquid secondary market depends entirely on sustained attention: consistent updates, clear milestones, a professional IR posture, and compliant outreach that doesn't stop after the raise. We give companies real cost guidance up front and work with their marketing teams to improve efficiency over time.
How ATS liquidity supports a major exchange plan, without replacing it
An ATS builds three things; a transaction record for price discovery, real shareholder engagement, and operational maturity in transfer processes and reporting discipline. It's evidence that the company already behaves as a public company should.
One more point worth flagging: Reg A+ can support an IPO directly to Nasdaq or NYSE. In a Reg A+ Direct Listing, no shares get sold at the listing event itself; the sales happen earlier, as capital is raised ahead of it. Post-listing liquidity depends entirely on how well the company has been marketed and how compelling it is to investors by that point.
Timeline expectations
Plan on roughly 12 months from SEC qualification to cost-effectively fund a Regulation A+ offering. It's possible to raise capital in a Reg A+ much faster when you already have a large following of fans or happy customers - as was the case with the March 2025 IPO of NewsMax via Reg A+. They fully funded in three weeks. SEC Qualification itself moves faster: the SEC has cleared some offerings in as little as two weeks, though the average after filing runs closer to 60 days.
Can you raise more than $75 million?
Yes, sometimes. Regulation A+ caps issuers at $75 million per 12 months, but companies that need more often pair it with a Reg D offering, which has no dollar cap. That combination requires careful legal structuring.
The system, not the shortcut
A real path to liquidity runs through Regulation A+ execution, transfer agent operations, ongoing reporting, ATS readiness, sustained investor marketing, and, eventually, steps toward OTC and a major exchange. We coordinate that end to end with the right specialists and advise on how to use them well. None of it is effortless, and nobody who tells you otherwise is selling you something useful.
If you want to explore activating an ATS for your Regulation A+ shares and align it with a broader IPO or exchange plan, email [email protected]. Include your industry, traction, audit status, target raise size, and where you stand on a Regulation A+ filing.
Manhattan Street Capital is not a law firm, valuation service, underwriter, broker-dealer, or Title III crowdfunding portal, and we do not engage in any activities requiring any such registration. We do not provide advice on investments. Manhattan Street Capital does not structure transactions. Do not interpret any advice from Manhattan Street Capital staff as a replacement for advice from service providers in these professions. When Rod Turner provides advice, it is based on his observations of what works and what does not from a marketing perspective in online offerings. Rod does not tell the audience what to do or how to do it. He advises the audience on what is most likely to be cost-effectively marketed online. The choices of all aspects of companies' offerings are made by the companies that make the offerings.
Rod Turner
Rod Turner is the founder and CEO of Manhattan Street Capital, the #1 Growth Capital service for mature startups and mid-sized companies to raise capital using Regulation A+. Turner has played a key role in building successful companies, including Symantec/Norton (SYMC), Ashton Tate, MicroPort, Knowledge Adventure, and more. He is an experienced investor who has built a Venture Capital business (Irvine Ventures) and has made angel and mezzanine investments in companies such as Bloom, Amyris (AMRS), Ask Jeeves, and eASIC.
