Subject: FILE NO S7-24-20
From: Martin Ward
Affiliation:

Feb. 04, 2021


In response to the new regulations the SEC are considering regarding Rule 144 Holding Period and Form 144 filings SA Release No. 10.911 (Exchange Act Release No. 90773, 2020). We have great concern over the SEC’s consideration of extending the current holding period for Rule 144 as it will remove access to the convertible loans that we as a growing OTC QB company rely on to obtain funding for our growth. The convertible loans are essential funding for us and companies like us giving access to equity at an early stage in in our trading whilst giving the investors a more secure route to providing the funding. Our concern is that the proposed change could lead to a reduction in these type of convertible loans and that will potentially be harmful to us and companies like us in the future.
 
 
Martin Ward FCA
CFO
Touchpoint Group Holdings, Inc.
martin.ward@touchpointgh.com
Tel: +44 (0)7785 334441