June 27, 2007
The elimination of the use of Rule 144 for companies that are or were shell companies will completely choke off funding for small companies. The "Baby" is being thrown out with the bath water. Some small companies don't have the $$$ for the formal registration process....
Why would any investor buy a Reg. D from a small nonreporting issuer that was once a "shell" company? Under the proposed rule in Section 6, they could NEVER sell their stock under the proposed rule
Maybe another approach could be considered, such as a requirement that they file financial reports in an alternative publicly available forum such as the pink sheets. Wouldn't that be close to "current and adequate"
information available with appropriate risk disclosure? After all, integrity of the financial markets is based on "risk and materiality".
Why not impose the strict standard on "Control" stock as opposed to "restricted" stock?
Many times it comes DOWN to money for the little guy, trying to build value and a real business, who can't afford to go to the "big boys" on wall street and can't afford the lawyers and accountants for 12g status...
GIVE THE LITTLE GUY A BREAK... AND CONTINUE TO STAMP OUT FRAUD