Subject: s7-02-23: WebForm Comments from Kent Woo
From: Kent Woo
Affiliation: CPA, CFA

Feb. 21, 2023

February 21, 2023

 While I fully support strengthening the rules around SEC employee investing and trading, the timing of trading restrictions on SEC employees borders on ridiculous. Under Chair Shapiro, employee trading restrictions were greatly broadened to effect all SEC employees regardless of whether they are or are not involved in an issuer investigation. Those increased restrictions were put in place in what can best be described as a knee jerk reaction. Personally, as a result, I've been restricted from liquidating a security going on five years even though I have no involvement in the investigation and have no access to any SEC insider information on the issuer. Apparently, persons committing fraud are generally afforded the benefits of a five year statue of limitation, but honest SEC employees saving for retirement are not.