October 14, 2019
These proposed changes (File #S7-14-19) appear to threaten/punish the many legitimate small public companies that not long ago were incentivized by the SEC (Form 15) to stop filing so they could mitigate the asymmetric crushing costs (on small firms) imposed by Sarbanes-Oxley.
Just as there are many publicly traded large market cap companies that continuous lose money there are many non-reporting companies that turn a profit and hold significant future promise. Simply seems incredibly unfair/unwarranted to potentially punish some promising small businesses (and their shareholders) which will no doubt occur should these proposed changes occur.
As an alternative to these proposed changes I suggest that the SEC require that broker/dealers present a warning sign (of potential risks due to lack of information, potential fraud, etc) to any client who wants to transact in a non-reportable security. The client would have to acknowledge willingness to accept the risk by checking Yes (to proceed with their transaction) or No (to cancel the pending order).
Please be sensible,
Alex Toppan
Connecticut