From: Melvin Pereira
To Whom It May Concern:
We understand that OTC Markets has filed a ‘Petition for Rulemaking’ concerning Reg. A and its use by Fully Reporting companies.
As a non-reporting company working towards becoming fully reporting, we’ve investigated the use of the Reg. A as a viable option. Noting that this is an exemption accessible solely for Pink Sheet companies, becomes somewhat discouraging to us in our endeavor to become fully reporting.
With Reg. A, a company gets an opportunity to avoid falling into the vicious trap of the micro-cap market’s most notorious funding vehicle... Convertible Notes. With Reg. A, companies get to have greater oversight over their future and destiny. With Reg. A, there is an accessibility to much more capital and greater controls to protect companies against dubious predatory investors. To afford this type of funding tool [Reg. A] only to non-reporting companies, and not permitting solid SEC reporting companies to benefit from the same tools... you, the Securities and Exchange Commission, is in effect perpetuating — or at least assisting with such — the continuous demise of the micro-cap markets as a whole.
Non-reporting... Fully reporting... at the end, guys like me just want to build good solid companies for the public market community. If we’re going to take the leap of faith and believe that becoming an SEC filer is that much better than not being so, despite the cost, then give reporting companies a fighting chance! Seriously..., don’t you want to encourage us to become fully reporting SEC compliant companies?