October 5, 2019
I am strongly opposed to this proposed rule change. It would harm (not help) serious investors in legitimate OTC dark companies. I own stock in several such companies, including Goodheart-Willcox (GWOX), Hershey Creamery (HRCR), and Moro Corporation (MRCR), among others. What would it achieve to prohibit a trading market in these securities? The SEC is trying to paint with far too broad of a brush. There are many profitable, honest companies that are reluctant to disseminate their financial information. At the very least, please consider a grandfathering exception, so shareholders of legitimate companies that have enjoyed a trading market for many years are not cut off entirely. It would be very beneficial for the SEC, in my opinion, to get the informed opinions of veteran investors who have substantial real-world experience related to this area. Anyone who has such experience would see the harm of implementing this proposal.
I understand the SEC's goal of eliminating fraudulent companies accessing the public market, but this rule is like tossing a hand grenade whose shrapnel will hit many innocent parties.