Subject: File No. S7-14-19
From: David Schiff
Affiliation: Founder and Editor of Schiff's Insurance Observer

October 22, 2019


Dear Sirs,

I have been an investor for more than forty years, and have, on quite a number of occasions, become a shareholder of a company that doesn't publish financial information. Many of these companies were substantial (and all were valuable), but for one reason or another didn't publish information.
I am also a passive investor in a partnership that invests in such securities.
I believe that the SEC's proposal is misguided and not in the interests of investors. It will make many valuable securities less liquid, or even valueless.
Rather than write a long comment, I will say that I am in agreement with the comments written by Lawrence J. Goldstein, Jim Rivest, David I. Waters, James E. Mitchell, and many other opposing this rule.

Sincerely,
David Schiff