DD Support Board and Research Team

[janice shell]

Okay. I agree that their proposed rule, if adopted, will defang convertibles as they work in the OTC market.

I've also been thinking about what they say about not requiring insiders of Pinks that have no registered stock to file Forms 144, saying that in any case only 1% of them had done so in recent years. I know we discussed that before, and you advanced a reason.

But... Isn't it likely only 1% of insiders of those companies file Forms 144 simply because they don't think they have to? After all, they don't have to file Forms 3, 4, and 5 because they aren't registrants. The same is true even of Securities Act registrants.