September 24, 2019 Via Electronic Submission Securities and Exchange Commission 100 F Street, NE Washington, DC 20549-1090
[email protected] Re: Comments to the Concept Release on Harmonization of Securities Offering Exemptions (File Number S7-08-19) OTC Markets Group1 is pleased to submit this comment letter in response to the Securities and Exchange Commission’s (“SEC” or the “Commission”) Concept Release on Harmonization of Securities Offering Exemptions. As the operator of markets where over 10,000 securities are traded, and as a publicly traded company ourselves, OTC Markets Group supports the benefits of public markets and their capacity to create capital growth opportunities for companies and investors. Public trading markets serve a basic purpose: to support investors that lawfully own, or would like to own, a piece of property – in this case, shares of a company – and their fundamental right to trade that property with interested counterparties. The ability of a shareholder to walk into a broker’s office, deposit their shares, and trade through their brokerage account has long been a central aspect of property ownership. Restrictions on an individual’s ability to buy or sell securities are a reduction of private property rights. As public trading has grown more complex over time, so too has the web of regulation designed to protect investors and promote orderly markets. These rules of fair play support our economy and have made our capital markets an example for the world to follow. We must also recognize that well-meaning regulation comes with a significant burden that has reduced the use of registered securities offerings, raised the costs of being SEC reporting, and lowered the number of companies that choose to be public.