October 26, 2019
I do not believe the proposed changes would be helpful in protecting an investor in "dark" companies. I have had little problems investing in these companies. It takes some extra work in that you sometimes need to reach out and contact them for information. The bigger problem is with the companies that put the information out there and are lying to promote their stock. Filing forms and then filing an amendment afterwards.
Taking away the ability to trade the stocks and making them even more illiquid would have very little effect on a bad actor and punish the legitimate companies and the current shareholders of those companies.
Requiring annual reports to be published and available either online or mailed to shareholders is really the only requirement I would make of the companies. Some are hard to get or they make you sign non-disclosure agreements because they fear sending the information allows for trading on non public information. In these cases you have to buy shares before you can go through that process to see the annual report. Obviously without knowing whether or not it is a good investment yet.