Subject: Regarding the proposed amendments to 17cfr240.15c2-11
From: David Aldridge
Affiliation:

October 1, 2019



(Hi I wrote that and I’m coming up here to emphasize that it’s kindve long. But bear with me please:) 

Hello, 


I’d like to thank whomever in advance for setting aside the time to read this. I know you all are busy and I appreciate folks on your end making yourselves available. 


I’m opposed to what’s being proposed. I could be far too wordy about it but in a nutshell I don’t like the idea of fiscal powers being further consolidated. What I mean is that from an open market investor’s perspective it’s always going to feel like an uphill battle...there’s so many variables and moving parts in play when making decisions and there always will be. But what’s being proposed won’t stop corrupt people working over the average person. On the surface it seems as though this is to steer interest towards reporting companies but reporting companies can issue, clear and liquidate debt more smoothly than securities that are currently exempt from filing (via 15-12g’s). Funders and forces around funders already dominate our world...in many instances they dominate the company’s and executives as well. I could spell that out in a lot more detail but you all know far more than me.  


As it stands now if you’re a thoughtful speculator who maneuvers based on public information you can employ an array of strategies at once on different fronts..Sure some of the market is dim witted and behind regardless but another portion of our market maneuvers based on rumors and they don’t speculate very much at all. I mean some people aren’t as good at using research to detect upside or downside and they profit quarter after quarter by reacting to rumors and folks with their “ear to the ground”. If you all make it to where we can only realistically steer resources towards reporting companies then you’re basically empowering funders and the funding cycle...meaning if those types of securities and set ups see an influx of liquidity and everyone else is punished then trading cycles will revolve around note conversions and awareness campaigns that are geared around providing funders/pertinent parties with the strength they need to liquidate; AND you’re empowering the little minions who are latched onto those proverbial teats...ala the people revolving around rumors and the tiers of traders behind them...in addition to those folks being rewarded monetarily they’ll be continually rewarded with clout as well as the dimwits will follow them as though they’re an embodiment of savvy investing. 


Cause 1 thing is for sure corruption is hard to fight and you certainly won’t do anything other than empower the most capable+corrupt forces by doing this...let’s look at the recent funding hurdles we saw implemented Spring ‘18 as an example. I have no idea how or if that differed in practice compared to what was talked about in theory but the market saw that as “the biggest funders got bigger”....cause clearing hurdles were in place but there’s a few names out there who kept liquidating full steam ahead. They even got to go around buying debt/notes for pennies on the dollar from smaller funders who were in fact hindered. The regular Joes let their guard down as though no dilution would take place below .01 and otc liquidity seemed to revolved around rumors and campaigns (extensions of the big funders). 


Like you all, I don’t like fraud, but unlike you all I don’t have the resources to take any measures. The amount of fake news on websites and twitter pages was shameful for a while...and the recent fake disclosure on Nevada situation was unreal. But if little old me can spot patters in the open market and I can tell who to avoid or pay attention to how can you all NOT see patterns surrounding the fraud I highlighted. You all probably have access to shareholder lists etc and over time I guarantee blatant patterns would be revealed. The answer IS NOT to punish anyone in or around a dark security....you can be a lot more proactive in surgical ways without funneling all of us into reporting and thus dilutive stocks. And I don’t envision you all caring very much about what you’re projecting but you’ve already telegraphed that delinquent filers can get suspended at anytime...companies on literal budgets scrambled to go dark trying to offset the risk of suspension   and now they’re to be punished for going dark? Now that I’m thinking about it are the states of NV and WY incentivizing you all to take these measures? I know how expensive it is in most other states to file, if they can’t remain dark and they can’t afford to redomicile then what? they’re toast? 


The reason I’m reaching out and making this attempt is because the majority of me believes that you all do care about small investors...the majority of me believes that you do in fact care about fraud. These proposed actions simply do not protect us. Not in real time and not big picture. Sure scumbags make effort to “pop” dark securities but these “pops” are usually taking place without dilution. It’s not perfect but it’s not really fraud compared to actual fraud. Not that my suggestion will be considered but the SEC and OTC already makes us hyper aware of how volatile if not dangerous these securities are..meaning people really do know that they’re risky. Plus in the trading community newer people are taught to trust less and less. Fraudsters or at least liars get outed on our end and these facts are palpable if not measurable in the over all market. That sounds drastic to say but I’m serious you can see that runs are less and less sustainable these days and it’s entirely due to seasoned investors shooting straight and newer investors being skeptical. More so than what we used to see even just 5 years ago. 


I don’t know what else to say other than the majority of people who trade dark securities are simply people wanting to take long term stances without feeling like dilution or algorithms will change the landscape. If you want to stop the fraudsters then stop them. We’re all thirsty to see them stopped...we’re thirsty for an ever improving market. People will help you. But this is not the way. 




Regards, 


David Aldridge [redacted]