Feb. 09, 2021
Ms. Countryman, I would like to express my concern with proposed amendment to Rule 144. The OTC Markets is platform that allows small and emerging companies to grow with access to capital not available to private companies. The proposed change would eliminate our ability to raise funds. Raising funds through a convertible note allows us an option to pay off the note within 6 months, which we often do. The alternative would mean either not being able raise capital or we would need to register the shares. This is not only a long and costly effort; it translates to immediate selling without giving us an opportunity to use the proceeds of the funding to raise our market cap prior to lender selling. Convertible notes give us the opportunity to invest the capital raised and after six months, we decide, based on the stock price and existing circumstances, if we would allow the note to convert to repay with cash. Furthermore, the speed and which we can receive funds from a convertible note is critical as we have over one hundred employees and that can be a decision on whether to lay off employees. For these reasons, I pray you decline making the proposed amendment to Rule 144. Thank you. Regards, ANSHU BHATNAGAR CEO Verus International, Inc.