From: Michael Chesler
Sent: July 13, 2016
Subject: file S7-06-16

I am a stockbroker and investor. Have been a broker since 1982. I am writing to voice my complaint to the SEC regarding the fact that the SEC allows public companies to completely disappear from view by filing form 15 with the SEC, claim the company has fewer than 300 shareholders and forever terminate all public information. I have watched the collapse in value of every single company that files to disappear. I am amazed the SEC allows this. Especially when a company claims fewer than 300 shareholders by counting all street name holders as one shareholder. Any brokerage firm could hold millions of shares in XYZ corporation. 5,000 different accounts could hold shares in this XYZ company yet the SEC colludes with XYZ company by allowing XYZ to claim 1 shareholder. This is beyond belief. All companies have a fiduciary responsibility to maximize shareholder value. How can they and file form 15 and disappear from public view? Insiders now can buy the shares of frightened shareholders cheap as the stock in question collapses as a result of this (what should be called CRIMINAL) filing with the SEC's APPROVAL. 
Let me provide you with but example.
SIMA .pk... Sonics and material corporation went public at 5.00 per share in 1996.
At the time they had revenues of 9.6 million and 262,000 in income. and 3.1 million in cash with little to no debt.
For the year ended June 2015 revenues are now 20 million and income over 2 million. Cash stands at 16 million or 4.67. Book value is 6.86. Little debt. I did manage to get financial statements after several calls. I am a shareholder. The pinksheets listing carries a grey market designation and Fidelity a large clearing firm does not allow and restricts any buying in securities with a "stop" , "grey market" or "skull and crossbones" designation. They,(Fidelity) do no due diligence but their policy is to restrict the purchase of securities with those credentials.
The most recent trade in SIMA, Sonics and Materials was .20 cents. 10,000 shares were sold by some shareholder who lacked information. Could the buyer have been an insider who knows a deal when he has the financials? Could the company steadily be repurchasing stock at absurdly low prices simply because NO ONE IS WATCHING? Absolutely. Form 15 is a license to do whatever, with no public scrutiny. So what price would SIMA trade if it was fully reporting? The original IPO price of 5.00? Maybe. In a collapsing market. Less than book and awfully low P.E. ratio. Maybe 10 would be a fair price. 


As a broker, a dark company called me asking me to make a market in their stock. When I told the CEO I'd need current financials for us to make a market in the stock he said they do not provide those. My response was "so you want to buy the shares from shareholders with the information you have from the scared shareholder who has no information but watches the shares spiriling down. Isn't that just a little unethical?" He hung up on me.

PLEASE SEC, HELP. We are drowning in companies going dark and stocks that become worthless but are truly NOT. Look again at my SIMA, sonics and Materials example.

Incredibly FRUSTRATED, Thank you,
Michael Chesler