Subject: File No. 265-31
From: Brad Christensen
Affiliation:

Oct. 14, 2018

“If a company is a dark company and listed in the OTC market and hasn’t put out financials for six months, maybe it shouldn’t be quoted or offered to retail investors.” (source: Brett Redfearn, SEC regulator's division of trading and markets in a Bloomberg October 1, 2018 article) 


I strongly oppose this idea. I am a retail investor with over forty years of experience investing in the stock market with much of it in the dark space. There are many small cap and micro cap companies that only produce financial statements on an annual basis. These include companies with historical profits within such stalwart industries as insurance and banking. This would undoubtedly force the thousands of legitimate dark companies to either produce quarterly reports at great expense while others would decline to endure this burden thus no longer trade on any exchange. Insiders would unfairly benefit. Liquidity would disappear. As such, this idea would stifle capitalism.


This idea would not protect retail investors. The unintended consequences are that it would clearly provide less overall transparency and be a great disservice to those investors who participate within the dark company space.




Brad Christensen