* The Hippocratic Oath urges doctors to weigh potential benefits against risks to prevent patient harm. Similarly, the SEC needs to avoid unnecessary harm to investors when enacting a rule. * Rule 15c2-11 is an example of a rule that largely will have met its objective. However, it has caused a small segment of the market undue harm. Thankfully, the commission is reviewing Rule 15c2-11. * My hope is that preferred issues will be treated as fixed income investments and as such eliminated from Rule 15c2-11. * Preferred share investors are largely retail investors seeking safe yield in the same way as bond investors. * Both exchange-listed and OTC Preferred shares do not trade like equities. They fluctuate on the same market, economic and company-specific news that a traditional fixed income product does. * 15c2-11 exposes retail preferred investors to far more volatility than they may have envisioned. * Future acquisitions of publicly traded companies by private entities will likely lead to retail investors experiencing unexpected financial loss as a result of delisting. * Preferred shares are largely linked to well-established and financially sound banks, insurance companies, utilities, etc. They trade like fixed income instruments and are invested in by retail investors seeking bond-like returns. By allowing preferreds to fall under 15c2-11 the commission has and will continue to cause harm to retail investors.