December 18, 2019
We are commenting to express our disappointment with regard to the proposed rule change regarding the publication or submission of quotations without specific information. As investors in small companies with sometimes limited financial information and/or records readily available, we find the proposed rule change to be detrimental to investors such as our firm, its clients, and its funds which benefit from the regular quotation of shares which are in general lightly or infrequently traded in the public markets and/or over the counter.
We believe the proposed rule change will negatively impact our business and our clients through reduced liquidity and transparency of pricing in the marketplace while simultaneously driving regulatory costs for small firms that may find it necessary for this or other reasons to bear the expense of filing unnecessary financial information to maintain regular quotations.
We oppose this rule change as one that would be detrimental to the market while having little to no positive effect for investors in such smaller and less frequently traded institutions.