November 27, 2019
This message was sent securely using Zix® Dear Chairman Clayton: I write to express my opinion on the proposed rule change for OTC traded businesses. While I believe the SEC has pure intentions, the repercussions of the proposal as drafted I believe would have dire consequences for some of our country’s best companies. Specifically many annual reporting companies on the OTC are some of our strongest companies judged by corporate duration, financial strength and stakeholder focus. These companies are not wedded to the capital markets so have built themselves self funding capabilities, consistent profitability, strong relationships in the community, tangible assets and an anti-fragility that provides corporate ballast often unavailable in the low end of quarterly reporting companies. Specifically my concern is that some of the capitalists running these strong foundationed companies would use the amendments to the current Rule 15 c2-l l, that could harm individual investors if they use the quoting vacuum in order to increase their control of their managed companies. While control strategies are apart of our system, the prices from their minority shareholders would no longer reflect the value of the corporation let alone a control premium. Instead, we believe a likely consequence is exponentially larger minority discounts simply by declining to provide the company's financial information. Sincerely, Eric H. Speron [redacted] This message was secured by Zix®.