July 13, 2016
Dear Sir or Madam,
The SEC claims that any company with less than 300 registered shareholders can cease filing financial statements and escape regulatory burdens. This is called "going dark." The theory is that a company this small should be considered privately held. I don't disagree with the SEC's logic, except for one area, the type of shares the SEC counts as 'shareholders'. Rather than requiring less than 300 stockholders of records, the SEC should amend this to less than 300 beneficial shareholders.