Subject: File No. 4-639
From: David Lopez
Affiliation: Spartan Securities Group Ltd.
October 13, 2011
I have listed topics for discussion as follows:
- NSCC illiquid fee - the fees direct detriment to small businesses' ability to raise capital and have stifled shareholders access to liquidity.
- DTCC placing "chills" on deposits - adversely affecting shareholder ability to access liquidity in the open market.
- DTC not allowing OTC securities access to FAST (DWAC or DRS services) - though FAST is mandatory for NYSE and NASDAQ securities.
- FINRA audit activity and communications - brokerage firms now no longer allow micro-cap securities to be deposited by shareholders.
Spartan Securities Group Ltd