December 31, 2019
Ref rule 15c2-11.
Dear Sirs/Madam
I am writing to strongly object to changes to SEC rule 15c2-11 that will likely create an unintended consequence of any rule change.
I am a private investor who is active in unlisted OTC stocks that are far from the Wall St crowd or most investors. These companies are reputable often family controlled businesses that operate openly in many small and large cities throughout the US. Many have been around for 100 plus years and are well known and stalwarts in their respective communities.
In many cases they have historically ended up on the OTC and trade infrequently. In some cases managements and/or Directors are happy with their partial anonymity on the OTC and do not make it easy to obtain information or even their annual reports.
The proposed rule change will only give cover to such companies and endorse their lack of transparency. By making it a requirement for brokers posting markets in such stocks to obtain and distribute annual reports, they will be unable to do so because certain companies just won't provide them. Hence a shareholder or prospective shareholder is deprived of trading opportunities in such companies. This could also well lead to takeover offers by unscrupulous operators taking advantage of an uninformed marketplace.
I strongly urge you to not adopt this rule that will disenfranchise many investors that invest in these lesser known companies.
Yours Sincerely,
Peter Hayman