Subject: File Number S7-14-19
From: Philippe Goodwill
Affiliation:

October 1, 2019


I disagree with the proposed rule. 

Shell company information can be found on secretary of state websites. 

Shell companies might be the most honest investments in the OTC because a dead shell who actually becomes worth something has a good reason for the price to go up. 

There is always a catalyst for going up and there is always a catalyst for going down. Sometimes, with shell companies, this bearish catalyst is that dumb people find out what the real share structure is. While savvy investors already knew all of that. BECAUSE THE INFORMATION IS ALREADY PUBLIC. At least in Nevada, Wyoming, Florida, California and more. 

Of course the due diligence to be done by investors is different with these types of investments than a company listed on an exchange. Does this mean it should be banned? I think absolutely not. There really is a way for a nobody like me to make money all alone with the appropriate due diligence. 

Maybe owners of shell companies should disclose some information more, but the information is already public. It can be found. And that's the beauty of it. 

Of course some people lost money, I lost money, it's the stock market. Everyone who trades in the OTC knows it's high risk high reward. Why punish the smarter more savvy investors? I'm a nobody and I'm all alone. 

The idea of a small company who needs funding merging into a dead shell is the American dream. Anyone can make it big. The road exists. Sometimes this road is an entity going into a dead shell listed on the OTC. 

This is my hope for a better life. Please don't take it away. 

Thank you, 

Philippe Goodwill