Subject: s7-02-22: WebForm Comments from Daniel Kulodzik
From: Daniel Kulodzik
Affiliation:

Apr. 18, 2023

April 18, 2023

 I agree with the proposal.

Transparency, fair and orderly markets, and investor protections that apply to todays registered exchanges or ATSs are essential to market participants that use New Rule 3b-16(a) Systems for crypto asset securities.

Moreover, I support the statement that an organization, association, or group of persons that constitutes, maintains, or provides a market place or facilities for bringing together purchasers and sellers of crypto asset securities or performs with respect to crypto asset securities the functions commonly performed by a stock exchange as that term is generally understood under the criteria of Exchange Act Rule 3b-16(a), as proposed to be amended, would be an exchange under section 3(a)(1) of the Exchange Act and would be required to register as a national securities exchange or comply with the conditions of Regulation ATS.

I agree with the Commissions view that the Proposed Rules should apply to trading in any type of security, regardless of the specific technology used to issue and/or transfer the security.