From: Ian Park [ipark@ceocouncil.net]
Sent: Monday, June 07, 2004 2:56 PM
To: rule-comments@sec.gov
Subject: File No. S7-19-04


THE CEO COUNCIL
Washington DC
www.ceocouncil.net
Email info@ceocouncil.net
Tel. (850) 345-0946

June 7, 2004 

Division of Corporate Finance 
United States Securities and Exchange Commission 
450 5th Ave. NW 
Washington D.C. 20549

Re: Proposed release 33-8407

We are on record as opposing any regulation that does not adequately balance the 
interests of small public companies and their investors. The proposed changes in 
the regulations described in this release add significant costs to the capital 
formation process for small businesses and do very little for the majority of 
small public company investors. As such, we oppose them because they further 
hamper small business' ability to raise capital.

However, we see this proposed release as a potentially serious and adverse 
milestone in the relationship between the SEC and the small business issuer’s 
community. 

We in the small issuer community left the last SEC Forum with the impression 
that no new Small Business Issuer initiatives would be proposed.  When a 
significant change like this is thrust upon us with no advance discussion or 
warning, it causes us to believe that the SEC may have not been completely above 
board and honest with us at this year’s event.  

With this breach in communication, it is not a far stretch to conclude that the 
SEC is not adequately representing small business capitalization policy 
interests. 

We want to know when the SEC will stop taking an adversarial position against 
small issuers and come to the table openly and honestly so that a right-sized 
regulatory regime can be created for small public companies.

We stand ready to meet with you to discuss these issues at any time. 

Sincerely,

The CEO Council
Steve Crane
Director


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Ian Park
Government Liaison &
Legislative Director
The CEO Council
850.345.0946
ipark@ceocouncil.net
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