October 10, 2019
Dear SEC Staff,
I have read with great alarm the SECs proposed changes to 17 CFR 240,15c2-11. I would like to strongly urge the SEC to reconsider the nature and scope of these changes on the grounds that the changes, as written and proposed, would have a devastating impact on holders of many legitimate non-reporting over-the- counter securities, resulting in extraordinary destruction of investors capital.
The proposed change is to be commended in its goal but the fact is that there are legitimate companies that fulfill their duties to shareholders that would effectively be eliminate from the public markets. There is potential for true economic destruction into the billions of dollars of capital if this change is made.
Thank you for your consideration in this matter.
Regards,
Bradley Grasl
Chief Investment Officer, Tiercel Capital Texas