October 3, 2019
Dear SEC,
This new rule would kill a large part of trading OTC stocks. Also a lot of people invested in so called "dark" tickers will lose large amounts of money if this new rule is being adopted.
People trading OTC stocks are aware of the risks. Much info can be obtained via www.otcmarkets.com and (online)brokers also make you aware of the risks trading pennystocks.
The real problem are the highly dilutive stocks, which are always current with their financials but their business IS selling shares. With their yearly r/s and a/s increases THESE are the ones you should be after... These are the ones taking millions from the markets to satisfy their greed. Tickers which filed form 15 should not be affected with your new ruling.
Therefore proposed rule S-7-14-19 should not be adopted. At least not with retroactive effect. This is not Nasdaq, it is OTC...
Best regards,
R. Berkvens