Aug. 02, 2021
To Whom It May Concern: I am a private investor focusing on the small and dark stock space. I own many stocks affected by the recent change to SEC rule 15c2-11. Recently, a number of brokerages have communicated their actions as a result of this rule and unfortunately all of them are backing away from trading. I can't find a single online brokerage that will allow me to buy non-reporting stocks after your rule enforcement date of Sept 2021. Whatever the SEC was hoping to accomplish with this rule change I can tell you many real companies are not going to change their ways. Combine the SEC rule change with the brokerages' reaction of blocking buys and this means many stocks I own can no longer be bought. There are real quality companies in this space, such as Hanover Foods, and this corner of the market is one place where a small investor can have a real advantage over big funds. Please do not disadvantage small investors by cutting off one area where they can find attractive valuations before large investors swoop in. I urge you to do two things: approve the otcmarkets' Expert Market exemption without a sunset provision as soon as possible so brokerages and the market can react. Without this approval brokerages cannot plan and carry out their business for clients like myself that would like to transact in this corner of the market. extend the adoption date of this new rule to give the market and brokerages time to adjust and approve necessary individuals Thank you, Jonathan Lichter