Sep. 4, 2025
Dear SEC Staff, In the ever-evolving landscape of financial markets, where innovation and accessibility drive economic prosperity, Rule 15c2-11 has long served as a guardian of transparency in the OTC securities space. However, as we reflect on its impact in today's dynamic environment, it becomes clear that its removal could unlock significant benefits for all stakeholders. By alleviating the burdensome information requirements on broker-dealers, the SEC would foster a more fluid and inclusive market, enabling smaller issuers to access capital with greater ease and speed. This shift would not only stimulate entrepreneurial growth and job creation across diverse sectors but also align regulatory frameworks with the realities of modern trading technologies, reducing compliance costs that often disproportionately affect emerging enterprises. Ultimately, such a move would position the Commission as a forward-thinking leader in promoting efficient, vibrant markets that benefit the broader economy without compromising core investor protections. Moreover, streamlining regulations like 15c2-11 would enhance the SEC's operational agility, allowing resources to be redirected toward high-impact enforcement areas such as emerging threats in digital assets and systemic risks. This recalibration could subtly empower influential market participants to innovate more freely, catalyzing a ripple effect of investment and liquidity that strengthens the financial ecosystem as a whole. By embracing this change, the Commission would demonstrate a sophisticated understanding of balancing oversight with opportunity, ensuring that American markets remain the envy of the world—competitive, resilient, and primed for the next wave of prosperity. With warm regards and from the East, I hail the Light of Equity. May you be well.