March 4, 2021
For File Number S7-24-20 Rule 144s revision of the holding period determination period for securities that are acquired when conversion of an equity or security that is not listed on a national securities exchange should be more specific to not confuse those reviewing the rule. In my opinion and not being a big time trader just your average Alic Rashidi. A national security exchange should be specified as to what the exchanges are and what the exchanges are not. For example the New York Stock Exchange, Nasdaq, CME, OTC Market, etc.. By being more specific with the proposed rule amendment you will be leaving out room for error.
To mandate electronic filing of form 144 is a step in the right direction to moving all things over to digital records. As for the commissions proposal to eliminate the requirement to file a Form 144 for resales of securities that are not subject to exchange act reporting I would like to see why this would be eliminated for issuers that are not subject to exchange act reporting. Would it make sense to do away with this permanently for both those that are subject and those that are not subject.