Subject: File No. 265-31
From: Christopher J DiIorio
Affiliation: Whistleblower

October 30, 2018

Once again, the grossly corrupt SEC sides with criminal activity instead of executing its MANDATE to protect the investing public. Or, as Jay likes to call them: Main Street investors. The latest example is found in a recent strategy by the SEC detailed in the October 1 2018 Bloomberg article: "SEC spots a way to starve the most suspicious penny stocks" written by Michelle Davis.

The SEC has decided to revoke the registrations of OTC shells only AFTER they go dark in filings with the SEC. isn't that great?
The SEC KNOWS that these OTC shells go dark AFTER massive fraud has already been perpetrated on the investing public (Main Street). In taking this approach, there is no accountability for large market participants who perpetrate the massive fraud. I have filed extensive TCR's detailing in great length this activity. In 3 such examples, the SEC had my information in hand for YEARS and did absolutely nothing.

Colorado Goldfields CGFIA, Mass Hysteria MHYS, and IDO Securities IDOI.
Prior to going dark in SEC filings each of these securities were nothing more than money laundering shells. Where Bag Men like barred (not exactly) Curt Kramer, Asher,KBM,Vis Vires, Jabro et al and JMJ/ Justin Keener as well as Hanover/Magna,Tangiers/Iconic et al dump billions of worthless certs on the investing public through willing executing BD'slike NITE who facilitate these sales by abusive naked shorting that generates the vast amount of trading profits at NITE. How does revoking a shell registration AFTER the fraud has taken place do anything to execute its Congressional MANDATE to protect the investing public? It doesn't. But, it's worse than that. Because taking this approach does nothing to deter the criminal activity.

In 2017, Knight/KCG/VIRT traded more than 2.7 TRILLION shares of these shells. No doubt, many of them are future candidates to have their registrations revoked.
It gets even worse. My TCR's detail the balance sheet implications for NITE as a result of this abusive naked shorting (manipulation). Knight was insolvent in August 2012. The SEC bailed them out. KCG was insolvent in September 2014 and July 2017. The SEC bailed them out. VIRT is insolvent in October 2018. The SEC is again bailing them out. As a result the investing public has taken a back seat to criminal entities like NITE et al. Jay Clayton must resign immediately and the SEC must use its emergency powers to halt trading in VIRT as it poses a clear and significant risk to the investing public: Main Street.

In addition, the SEC must shut down FINRA and the FINRA outsourced OTC market as well as the OTC parent OTCM. OTCM is run by Cromwell Coulson who recently served as Chair of the FINRA Market Regulation Cmte. A complete and absurd FRAUD. A Director of OTCM is Andrew Wimpfheimer. A former OTC shell trader at Knight. he also serves on the OTCM Audit Cmte. Which explains why OTCM ITSELF is not a fully reporting SEC company.

The SEC is more than grossly negligent in executing its mandate to protect the investing public. It's worse. The SEC actively facilitates the fraud on the investing public and initiatives like this are further evidence. Instead of siding with the market participants who buy SEC protection, the grossly corrupt should side with Whistleblowers like me who are on the side of the investing public: Main Street Jay.

Cheers

Christopher Diiorio