Commentary from the Milken Institute Center for Financial Markets to the Securities and Exchange Commission on proposed changes to the registration requirements under the Securities Exchange Act of 1934 to implement Titles V and VI of the Jumpstart Our Business Startups (JOBS) Act. Specifically, we addressed proposed rules relating to the change in number of holders of record an issuer must have before it is required to register with the Commission pursuant to Section 12(g) of the Exchange Act.