Subject: Comments On: Amendment to Exchange Act Rule 15c2-11
From: Spiro Kalogeropoulos
Affiliation:

Jul. 28, 2021


To Whom It May Concern, 

Just wanted to add a comment to the Statement on the Adoption of Amendments to Exchange Act Rule 15c2-11 by Commissioner Hester Peirce (https://www.sec.gov/news/public-statement/peirce-statement-adoption-amendments-rule-15c2-11).  The commissioner asked that investors comment on any issuers that they feel should not be included in this amendment.  I have been an investor of Towerstream (TWER) for many years and feel that they are an above-board business that currently provides important Wireless Broadband services to buildings and areas that may not be able to receive traditional internet services (and who have also offered its wireless Broadband services for free to Manhattan residents during natural disasters in the past when standard forms of communication (fiber broadband and cell phone towers) were down).  I believe they stopped reporting earnings recently as a cost cutting measure as they have been increasingly attempting to aggressively cut costs in every way in order to keep the business going.  I'm hoping that they will potentially be a contributor to any kind of upcoming infrastructure legislation to promote increased broadband services to rural and urban parts of the country that are inaccessible for traditional broadband.  They do have equipment in the form of routers inside buildings and satellites on rooftops, so they are a business with hard assets on their customer's premises, so they're not just a "fly by night" services company.   I whole-heartedly agree with this Amendment to root out fraudsters and easy manipulation of OTC stocks, but also agree that it would be a good idea to create a qualifying tier within that group of non-reporting issuers that have hard assets as part of their business and that have also shown that the reason for not reporting is a part of a cost cutting strategy.  Towerstream (TWER), in my opinion, should qualify for this tier of OTC security and not be subject to de-publication of quotation information by broker/dealers. 

Sincerely, 


Spiro Kalogeropoulos