June 28, 2007
regarding item 6. removing reliance on 144 for shell companies for resale of securities both pre and post merger..
why does a non-reporting issuer have to become a 12G reporting company under your proposal?
isnt 12g voluntary? i feel that is rather harsh...
many small companies can't afford the lengthy process, paying lawyers and accountants, yet many of those companies are good, honest, hardworking people...
could a compromise be reached on that issue, maybe a requirement that all post merger issuers with a shell must go through the formal 15c-211 process through a broker/dealer or that they would be required to file financial reports at pinksheets.com or some other less onerous, harsh requirement. there would still be current and adequate information in the public domain.
the net effect is penalizing some shareholders who waited years holding their shares and small issuers who will have access to capital totally choked off
The commission in this proposal is forcing companies into a 12g status if they are to survive...something that many simply cant afford...
we are talking about the little guy, the ones with big ideas sometimes, who big time wall street has absolutley no time for...
WHAT A SHAME....