Subject: File No. S7-2026-08
From: Michael Draper

Re: File No. S7-2026-08, Publication or Submission of Quotations Without Specified Information To the Commission: I support the Commission's proposal to clarify that Rule 15c2-11 should refer only to "equity securities," but the proposal does not fully solve a serious remaining problem: legacy income securities and preferred stocks such as KTBA (CUSIP: 22080E205) and SLMNP (CUSIP: 808194302) can still be stranded on the Expert Market even when meaningful current public information exists at the parent-company or segment level. The proposal itself states that it would replace "security" with "equity security" and would not otherwise change the substantive information-gathering and review requirements for equity quotations. That is exactly why the Commission should use this rulemaking to address the treatment of seasoned trust certificates and preferred securities whose issuing entities are now embedded within larger SEC-reporting enterprises. KTBA is a trust certificate backed by BellSouth Telecommunications 7.00% debentures due December 1, 2095, CUSIP 079867AP2. The original KTBA prospectus was built around the premise that the underlying issuer was subject to Exchange Act reporting and that disclosure regarding the underlying debentures would come from publicly available SEC materials. Today, BellSouth Telecommunications, LLC is listed as an AT&T subsidiary. KTBA therefore illustrates the gap in the current regime: the underlying credit remains tied to a large public company, but the public quotation framework has not adapted to the reality that investors now look through a parent-company reporting structure rather than a stand-alone issuer structure. The expert market designation is extremely harmful to investors. For example, KTBA recently traded around $21.05, which implies a current yield of roughly 8.2%-8.3% on its $1.75 annual cash flow, while a public retail bond page for the underlying BellSouth 7.00% due 12/01/2095 bond showed a price around $104.83 and a yield of 6.67%. That spread is powerful evidence that Expert Market status is imposing a liquidity and access penalty on KTBA holders. The underlying bonds that KTBA holds are rated BBB by S&P and BBB+ by Fitch. Investors are not simply pricing BellSouth or AT&T credit risk; they are pricing the loss of normal quotation visibility, the loss of retail access, and the practical barriers to trading the security at all. SLMNP presents the same structural problem in a different form. LyondellBasell's own FAQ states that LyondellBasell Advanced Polymers Inc. is no longer a stand-alone publicly traded company, that it became part of LYB's Advanced Polymer Solutions segment after the merger, that information for that segment is publicly available on LYB's investor website and EDGAR, and that the Special Stock trades on the OTC Expert Market as SLMNP. LYB also states that the security pays cumulative dividends at a 6.00% rate on a $1,000 liquidation preference, has a fixed $848.27 cash conversion value, and is equity, not debt. SLMNP should not be trapped in the Expert Market merely because the issuing entity now sits inside a larger SEC-reporting corporate structure. In practice, retail brokerages do not permit ordinary investors to open new positions in Expert Market securities, and some sharply restrict even exit transactions. Fidelity says it blocks buy orders and opening transactions in Expert Market securities and warns that quote information may be limited and that orders may be delayed or execute at prices that differ significantly from the last price. E*TRADE says opening transactions in Expert Market securities are not permitted and closing transactions are allowed only in limited circumstances. When those policies are applied to KTBA and SLMNP, the result is not theoretical investor protection. The result is damaged liquidity, impaired price discovery, wider spreads, depressed valuations, and real economic harm to existing holders. The Commission is specifically asking whether it should re-propose or codify an expert-market exemption or exception, what effect the Expert Market has on liquidity and shareholders, whether brokers or dealers have ceased market making rather than comply with the amended rule, and whether additional categories of securities should be treated differently. KTBA and SLMNP are exactly the kind of securities that should inform those questions. They are not opaque shell-company common stocks or classic microcap fraud vehicles. They are long-standing income securities with known terms, seasoned holders, and meaningful public information available through parent-company reporting structures. I urge the Commission to adopt a targeted safe harbor or exception for legacy trust certificates and preferred securities like KTBA and SLMNP where: (1) the issuing entity is part of an Exchange Act-reporting parent company or its segment information is publicly available on EDGAR or on an unrestricted issuer website; (2) the security has fixed, well-defined payment terms; (3) the issuer is not a shell company; and (4) there is no recent Commission trading suspension or comparable red flag. The proposal already recognizes that information on an unrestricted issuer website qualifies as "publicly available." The final rule should make clear that parent-company and segment-level public disclosure can support normal public quotation for these legacy income securities. Retail investors should be allowed to buy and sell KTBA and SLMNP in a normal quoted market. The current Expert Market framework does not protect current holders of these securities. It penalizes them. Respectfully, Michael Draper