We urge the Commission to initiate a pilot program to investigate whether widening the MPVs for emerging growth companies will result in benefits to investors. We recommend that, at a minimum, such a program have the following characteristics:
- A defined measure, to determine whether there is a benefit to investors and capital formation
for emerging growth companies with reintroducing wider MPVs, will need to be determined.
We recommend a measure which could quantify overall liquidity, both displayed and enhanced.
- Utilize a statistically significant number of emerging growth companies to study the impact on
the secondary markets of quoting securities in MPVs greater than one penny.
- Establish eligibility criteria for companies to qualify for the pilot program.
- Allow the pilot program to operate for a sufficient period, a minimum of 2 years, so that firms
will have an incentive to make the financial commitment necessary to participate on a
commercially viable basis.