December 30, 2020
To the SEC: I am writing regarding proposed rule S7-14-19. I am deeply concerned with the proposed rule's potential impacts on non-reporting companies that continue to be listed and traded OTC. These companies legally do not report to the commission, having reached various thresholds that no longer require them to file reports with the commission per law. These companies continue to exist, provide annual reports to shareholders, pay dividends, and trade OTC. The proposed rule would effectively wipe out this area of the marketplace. It is ironic that the SEC is willing to wipe out billions of dollars of market capitalization and potentially cause significant and catastrophic loss to shareholders, simply to cover for a situation the SEC has allowed, and encouraged(!), to exist in the first place - the deregistration of securities and cessation of quarterly and annual reporting. Fundamentally, the proposed regulations create the absurd situation of allowing for a publicly traded company owned by shareholders to stop filing reports, and then disallowing any trading OTC, effectively wiping out remaining shareholders. This allows for, and encourages, insider looting of the non reporting and non trading company. I believe (and hope!) that these unintended consequences are not the goal of the Commission. Indeed, they are the exact opposite mandate the SEC is charged with. Has the SEC considered this impact? I would prefer for the SEC to leave the situation as is and allow investors to make their own decisions; however, if the SEC is determined to make changes I offer several options for your consideration: 1. Get rid of the nonsensical situation where shareholder of records are considered to be the broker holding for the investor at the clearing house, and not the individual investor themselves. This will make it much more difficult for companies to stop reporting and file form 15. 2. Allow companies to continue to de-register but require annual reporting at a lower standard. 3. Allow Investors to self-certify their willingness to trade stocks. Allow brokers to continue to quote the stocks to Investors who self certify regardless of current information available on those stocks. 4. Ban the paid promotion of penny stocks and you will solve about 95% of your problems. 5. At a minimum, grandfather any existing non-reporting companies, and allowing any company that files Form 15 or kicked off a larger exchange to be quoted and traded OTC for a minimum of 10 years. Again, I urge the SEC to continue the consequences of their actions on the OTC marketplace before moving forward. Respectfully, Ariel Ozick