July 16, 2016
Re: Item 201(B).
Disclosure of beneficial holders should be retained and expanded. This would a relatively minor burden on filers, as this information already exists and is quite easily searchable at "street name" holders such as brokers.
In addition, the SEC distinction between registered and "street name" holders, while well-intentioned, has led to some chicanery on the part of "dark" companies which resist, sometimes capriciously, shareholder requests for information on the grounds that they are not in fact shareholders since they are unregistered. The registration process needs to be streamlined or the distinction between "street name" and registered holders should be eliminated (registration, as you are well aware, may impose a substantial burden on shareholders in terms of expense and liquidity). While the under-300 rules does make sense in terms of filing burdens for small companies, it should not be used as a shield against legitimate shareholder interests.