Rule 15c2-11 originated in 1971 (49 years ago) and then amended in 1991 (29 years ago).
With the advent of online trading since 1991 where trading occurs in nano-seconds and numerous message board forums exist(ed) where the predators (*cough cough, sophisticated investors) feed on the prey, the unsophisticated investors, the SEC let 29 years lapse from the 1991 amended Rule 15c2-11 and now have a Final Rule for 15c2-11 that fails to aggressively prevent rampant frauds from inaccurate and inadequate information for stocks in the OTC marketplace. The miscreants will have no problem wiggling around the Final Rule.
Having read the Final Rule IMO Cromwell Coulson and all predators won a landside victory. The few civil prosecutions were and are a calculated cost of profiting from fraud.
Damn, with over 3,700 SEC Suspensions since 2010 virtually all of the suspensions occurred long after the predators looted the majority of unsophisticated investors. In my list-post I used a crude calculation that if each suspension had approximately 25 investors then approximately 92,500 unsophisticated investors got wiped out. At a loss of $1,000 per investor the combined losses were $92,500,000 over the last 10 years. At an average $5,000 loss per investor the losses would be $462,500,000. And likely much, much higher. And that's just the I-HUB investors.
The SEC had an opportunity to seriously and immediately protect unsophisticated investors with an effective, no wiggle-room Rule 15c2-11.
As I see it the SEC failed miserably.
To bite the worm of incite is to bite the HOOK of the antagonist . They win .
AI
