Jun. 29, 2021
Dear Madam or Sir,
I did find recently on a SEC proposal regarding - 'thin' traded securities and I am responding on your request for comments.:
https://www.sec.gov/rules/policy/2019/34-87327.pdf
My name is Paul Arssov and I am the founder and developer of the Decentralized web project. We are building a decentralized communication and advertising platform.
I am responding from the point of view of a start up project, which uses a blockchain which is capable of creating crypto-currencies, and is looking to raise a minimum amount of funds which are going to be used in development and marketing of the start up project.
Through Reg D, and Reg A+, the currently regulatory environment enables 'middle-men' companies to act as securities exchanges for blockchain/crypto related start up projects,
My proposal relates to Form ATS, System P - as quoted below.
This rule allows offering and trading directly from the web site of the issuer.
It is within the capabilities of blockchain/crypto related start up project to develop the technology to enable direct trading from their web site as an issuer.
Please respond with a feedback and comments to this initial proposal.
We are are considering a technology implementation of the regulation, but depend on a positive feedback from regulators.
Best regards,
Paul Arssov.
Decentralized web project:
connect - https://discord.gg/Zwp3Vs65dk
become our patron - https://www.patreon.com/decentralized_web
------------- document quotes - Form ATS, System P --------------
https://www.govinfo.gov/content/pkg/FR-1998-12-22/pdf/98-33299.pdf
!!!!!!!!!!!!!!!!!!!pg13 - g. System P is an Internet web site setup by an issuer. Through this web site,the issuer provides information toprospective buyers and sellers of itscommon stock. Prospective buyers andsellers post their identities, contactinformation, and the number of sharesoffered or sought at a given price. Theissuer makes that information, alongwith the date the information wassubmitted, available to prospectivebuyers and sellers. The participantscontact each other outside of the website to execute trades. System P is notincluded under Rule 3b–16 because itdoes not establish non-discretionarymethods under which buyers and sellersinteract.
pg16 - b. Exclusion of Trading SystemsRegistered as Exchanges or Operated bya National Securities AssociationThe Commission proposed to excludefrom the scope of Regulation ATScertain alternative trading systems thatare subject to other appropriateregulations. In particular, Rule 301(a)would exclude alternative tradingsystems (1) registered as exchanges, !!! (2)exempt from exchange
registrationbased on limited volume,1
pg20 - Alternativetrading systems operating currentlymust file Form ATS within twenty daysof the effective date of these finalrules.166Form ATS requests informationabout the alternative trading system,including a detailed description of howit will operate, its prospectivesubscribers, and the securities it intendsto trade. In addition, the alternativetrading system is required to describe its existing procedures for reviewingsystems capacity, security, andcontingency planning. Alternativetrading systems are currently required to report most of this information on PartI of Form 17A–23...
pg49 - theCommission proposed Rule 19b–5, atemporary exemption for SROs thatwould defer the rule filing requirementsof Section 19(b) under the ExchangeAct450for pilot trading systems (‘‘pilottrading system rule’’).451
..... the pilot trading system rulepermits SROs that develop separate,new systems that qualify as ‘‘pilottrading systems,’’455to begin theiroperation shortly after submitting newForm PILOT to the Commission ismerely an informational filing and a
...pilot tradingsystem would have to be‘‘independent - different securities, 24/7/365