Oct. 27, 2023
Vanessa Countryman,
Secretary, U.S. Securities and Exchange Commission
Re: File: 4-795, Petition for Rulemaking and Application for Exemption With Respect to Rule 15c2-11
Dear Ms. Countryman:
I am commenting on the subject petition to support the changes in Rule 15c2-11. I have been affected negatively by this rule. I am unable to purchase a particular stock that has "gone grey" due to them not reporting to the SEC.
I had researched (XXX) company stock in 2021 while it was listed on the exchanges (approx 500 shares at $3.95). This investment was a very small portion of my investments. At that time, the company had several engineering products and services. They sold off their product lines, resulting in cash for developing new products. As an engineer myself, I understand the time it may take for new product/service development. I was patiently holding the stock, understanding the timing may be years.
XXX was delisted and stopped filing with the SEC, essentially becoming a "grey market, 15c2-11" stock. I sympathize with XXX company as the SEC reporting costs to remain listed may consume most of their corporate funds. These funds may be needed for product development. Delisting may have been beneficial.
I have seen the stock rise from approximately $0.01 to $0.04 per share with thousands and tens of thousands in volume over the past few months. I would like to invest more, but can't.
The SEC can't save the public from the ups and downs of the market. I have lost 99% of my investment during the time the stock was reporting and listed. But with the 15C2-11 rule, there is no way for the public to invest in the same stock when it is low. By the time this is listed on the markets, much of the value compounding will be lost.