Aug. 02, 2021
dear sir, madam, I'll keep this email short because Jim Rivest, Marcus Frampton and others already voiced their concerns about this proposal more eloquently than I ever could, English not being my first language. I think the proposed expert market is a decent idea. However, at the moment it looks like this proposal will not yield any concrete results before September 28, the date on which the new rule 15c2-11 becomes effective. And I think that is bad. All major retail brokers apply the rule 'better safe than sorry', They do not want to tangle with the SEC and are already starting to ruthlessly restrict transactions in thousands of securities for every customer, accredited investor or not. It is unclear whether retail customers can trade and transfer (or even hold!) these securities after September 28. And this list include legitimate, profitable companies that do communicate with shareholders One does not have to be a genius to understand that this uncertainty will lead to panic selling, lower liquidity and lower prices over the next few weeks. And the only market participants who will profit from this are the ones not affected by the upcoming rule changes. In other words, the current state of affairs is going to be profitable for professionals at the expense of retail investors. With that in mind, I have two suggestions: 1. Push back the implementation date of rule 15c2-11 changes until there is complete clarity about the expert market and/or other exceptions to the upcoming restrictions and until these initiatives are implemented. 2. The expert market or another proposal should make it possible (and feasible in practice) for brokers to grant access to the expert market to qualified retail investors. regards, Writser Cleveringa Private investor the Netherlands