December 10, 2019
Re: Comment letter on SEC recent rule proposal (Rule 15c2-11) for Alternative Reporting Companies Meritage Hospitality is traded on the OTCQX under the symbol MHGU. We currently employ 11,000 people across 16 states, and generate $475 million in annual sales. 1. We support the SEC’s proposal that (i) a “qualified interdealer quotation system” such as the OTCQX can determine whether an issuer has disclosed current information and (ii) broker-dealers can rely on that determination. · Meritage Hospitality (OTCQX: MHGU) has been providing audited financial information, MD&A detail and press releases on any and all material events on a quarterly & annual basis (same as when we were full SEC reporting company, listed on AMEX) for the past decade. These disclosures include accompanying officer’s certifications as to the accuracy of financial and other information. Today, Broker/Dealers do not accept our Disclosures as being “current and available to the public” because the information is not filed with the SEC. 2. We support that OTCQX assertion that companies (not brokers or trading systems) should be responsible for the accuracy of the information they provide. OTC Markets role should be to ensure that the sources of information (the company officers and directors) are reliable and that the information is complete and in line with the Alternative Reporting Standards established by the OTCQX. Thank-you. Meritage Hospitality Robert E. Schermer, Jr. CEO Robert E. Schermer CEO 45 Ottawa Ave SW, Suite 600 Grand Rapids, MI 49503 616-988-8741 | Publicly Traded