October 10, 2019
Dear SEC,
I strongly urge you NOT to implement rule change S7-14-19 to do with blocking quotes for OTC companies which are not current on their information.
I own many such stocks in my Traditional IRA. If you stop quotes on these stocks I believe it will be catastrophic for investors who own these securities.
For example, at some point I will be required by the IRS to take money out of my Traditional IRA for the Required Minimum Distributions. What am I supposed to do if you go ahead with this rule? How will I be able to sell my stocks to raise the cash that I need?
I also own a closed end fund that owns some of these stocks. This fund publishes its net asset value each business day. Instead of being able to use recent stocks trades to value these underlying assets, the fund will presumably have to use some sort of "good faith" estimates. This will result in investors who own funds like this receiving less reliable information that they need to make information investment decisions.
Your proposed rule will also make it much more difficult for investors to accumulate shares in these companies. What if investors are trying to accumulate shares in order to try to get rid of a board of directors that they believe are causing harm to shareholders? This rule will have the effect of entrenching current boards and managements no matter how bad they are.
I would also point out that no one is forced to purchase shares of a non-reporting company. All investors who purchase shares in non-reporting companies do so voluntarily.
Please do NOT implement this rule change.
Thank you.