October 8, 2019
Dear SEC, I am a private investor and also have interests in several dark OTC stocks. I believe the above rule changes, which will prevent brokers from showing quotes in dark stocks will further decrease the transparency and cause a significant drop in shares prices and almost certainly will favor insiders in these companies even more than is currently the case. As you know, the increasing costs of listing a company (roughly $600-$1M annually) has let many company’s to go dark, in order to save costs, even though they are a legit investment. This cohort of company will not be a viable investment any moregoing forward, if this rule is enabled. Furthermore, I believe that managment teams of many smaller companies might be encouraged to go dark, in order to block legit activism or just to freeze out current shareholders. I believe these unintended consequence may far out way the potential benefit of preventing investors to lose money into fraudulent companies without being aware of the risk (which is minimal , since brokerage will notify you of trade a dark stock). Sent from my iPad