Aug. 01, 2021
To whom it may concern, I am a private investor focusing on the small and dark stock space. I own many stocks affected by the recent change to SEC rule 15c2-11. Recently a number of brokerages have communicated their actions as a result of this rule and unfortunately all of them are backing away from trading. See Schwab's announcement here for example: https://www.schwab.com/resource/otcexpertmarket. This is the important line from Schwab's announcement, "Ahead of the regulatory enforcement date, Schwab will o nly accept orders to liquidate positions (i.e. no new buy orders) starting in late August 2021." I am sad to say I can't find a single online brokerage that will allow me to buy non-reporting stocks after your rule enforcement date of Sept 2021. Whatever the SEC was hoping to accomplish with this rule change I can tell you many real companies are not going to change their ways. Combine the SEC rule change with the brokerages' reaction of blocking buys and this means many stocks I own can no longer be bought. TCOR for example posts financial results on their website and is currently selling for about 0.2x revenue, 0.4x book value, and 6x earnings yet no one will be able to buy it anymore. DYSL sends a full annual report to all sharesholders, is profitable and selling below book yet no one will be able to buy it anymore. I could go on. There are real quality companies in this space and this corner of the market is one place where an individual investor can have a real edge over the big hedge funds of the world. Please do not cut me off from my alpha. I urge you to do two things: approve the otcmarkets' Expert Market exemption without a sunset provision as soon as possible so brokerages and the market can react. Without this approval brokerages cannot plan and carry out their business for clients like myself that would like to transact in this corner of the market. extend the adoption date of this new rule to give the market and brokerages time to adjust and approve necessary individuals Thank you, Dan Schum