December 8, 2019
Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090 rule-comments@sec.gov Re: Preliminary Comments to the Publication or Submission of Quotations Without Specified Information (File No. S7-14-19). To the SEC: Beacon Redevelopment Industrial Corp. is a small issuer with its stock trading through the over the counter market under the symbol BCND. As to the SEC's proposals, Beacon agrees that issuers should need to publish certain information. However, Beacon is extremely concerned that the proposal will lead to additional abusive and monopolistic behavior by OTC Markets Inc. OTC Markets publishes a website at otcmarkets.com. Despite having no regulatory authority, OTC Markets requires exorbitant annual fees from issues to publish a simple PDF with their financial information. The cost is extremely prohibitive for small companies. If companies do not pay these outrageous and excessive fees, they are listed as "dark" or "defunct" and OTC Markets falsely claims that the company is "unable or unwilling" to publish financial details. Once labeled with this "dark" rating, many brokers will not allow their clients to buy or sell the security. The false label is placed even when companies publish their information voluntarily on lower cost locations such as their own website. If the SEC is going to mandate the publication of information by small issuers, it should open the EDGAR system to non-reporting issuers for filing. By opening EDGAR to non-reporting issuers to comply with any disclosure requirements, the SEC will partially reduce the burden to non-reporting issuers. However, forcing non-reporting issuers to subscribe to an overprice service such as OTC Markets will substantially impede operations of smaller companies. OTC Markets' disclosure program has not reduced fraud in any way. Rather, their service provides an extortionate service that illegitimate issuers are happy to pay for in order to have the "dark" rating removed so they can issue stock to their associates and have that stock traded by brokers. On the other hand, smaller entities that do not wish to pay for OTC Markets' disclosure services, are listed as "dark" even thought they are not engaging in such practices and are willing to publish their information through a free forum. Additionally important when considering implementation of the regulations is to remember that the disclosure requirements should not be as onerous as those imposed on reporting companies. Many OTC companies are not currently seeking capital, but their stock is traded to enable shareholders with an easy method to buy and sell their securities. The information needing to be disclosed should not be complicated or burdensome, but basic and easy for an investor to read. Finally, we refer the SEC to the Jumpstart Our Business Startups Act of 2012. Under the JOBS Act, it was made clear that the regulatory framework for smaller issuers was to be reduced, not increased. The SEC should comply with the spirit of the JOBS Act when considering the disclosure requirements. In conclusion, Beacon remains agreeable to some form of disclosure requirement; however, the SEC should tread carefully in imposing a reporting requirement that is onerous, strict, and that costs the issuer a large amount of money such as OTC Markets' service. EDGAR must be opened to non-reporting issuers if disclosure requirements are imposed. Al Gonzalez President Beacon Redevelopment Industrial Corp.