From: Saj Karsan
Sent: June 2, 2016
To: rule-comments@sec.gov
Subject: File Number S7-06-16

All beneficial shareholders should be considered shareholders.

Item 201(b) and Exchange Act Rule 12(g) do not require companies to recognize all shareholders.  Item 201(b) and 12(g) do not count shares held in street name as real owners of stock.  Rule 12g allows companies to deregister if they have less than 300 "shareholders" without so much as a vote and the SEC allows companies to conveniently forget about all shareholders held in street name.  

What this means is there could be 10,000 people holding stock through one broker and the SEC would only consider this to be 1 shareholder.  When the Commission first adopted Rule 12g5-1 in 1965, approximately 23.7% of securities were held in nominee or street name.  In late 2002, it was estimated that over 84% of securities were held in nominee or street name.