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Marlon Melson Jr. Comment On Regulatory Notice 25-06

Capital formation is the lifeblood of a thriving economy. It fuels business growth, innovation, and job creation. In the United States, however, an outdated and increasingly overreaching regulatory framework—specifically SEC Rule 15c2-11—has become a barrier rather than a bridge to economic vitality. Originally intended to protect investors from fraudulent or opaque over-the-counter (OTC) equities, the rule’s broad application now hampers legitimate capital formation, restricts retail trader access, and disproportionately disadvantages small businesses.