Subject: File Number S7-14-19
From: Dan Schum

October 7, 2019

Dear SEC, 

I urge you to rethink your rule change S7-14-19 to do with blocking quotes for OTC companies not current in their information.  This would have disastrous consequences for many legitimate companies and their shareholders.  I understand you are trying to provide more transparency but this would be throwing out the baby with the bathwater.   

If you follow through with this you will be do serious damage to many of the shareholders you are supposed to protect.  Stock prices of dark OTC stocks will drop into the toilet.  Many individual investors, myself included, focus on these types of stocks because they are one of the only places you can have an edge over the large funds.   

There are many real companies in the OTC space that do no provide any information to the SEC or to OTCmarkets.  Some post reports only on their website (IOMT), some post updates on their website (AGTT), some mail out reports to shareholders (ADDC).  Some deliver reports only when asked (SIMA).  Some mail quarterly news updates to those who ask (EKCS).  The list goes on.   

These companies enjoy operating in the shadows.  They are not going to change their ways because you stop quotes on the stock.  They'll welcome the low price to just buy themself.  You will be hurting shareholders.   

These are all small companies that legally de-registered from the SEC using your rule 12g.  How can you allow a company to de-register then turn around and punish them?  On the one hand your rule 12g explains that it's perfectly OK for a company to stop communicating with shareholders and now with this new proposal you are going in the complete opposite direction. 

You should instead focus your attention on two things: 
Change your ridiculous "shareholders of record" definition which is so often exploited by companies to disappear.  There could be thousands of beneficial shareholders but you will consider them to be only 1 if held in street name.  You allow fraud all the time with this rule.  If you really want to protect shareholders start by counting us all!  You can read my prior SEC comment on this subject here: 
Give companies a cheaper way to stay SEC reporting.  So many companies de-register from the SEC due to the costs.  I have heard estimates ranging from a few hundred thousand dollars to over a million.  It's no wonder a tiny company wants to de-register.  Some of these companies have only a few employees and many have market caps less than a few million dollars.  You should offer a low standard of reporting.  Something like the OTCmarkets limited information tier that only requires an annual report.  It would be easier for companies to say current while allowing them so save money.   
Please reconsider the rule.   

Dan Schum