Feb. 24, 2023
February 24, 2023 Dear SEC Commissioner, As a retail investor, I am writing to share my thoughts on the proposed amendments to the Supplemental Standards. I appreciate the SEC's commitment to enhancing consistency, timeliness, and accountability in employee reporting of purchases, sales, acquisitions, and dispositions of securities. However, I have some concerns about certain aspects of the proposed amendments. Firstly, I would like to express my support for the prohibition of employee ownership of Financial Industry Sector Funds. I believe that this is an essential step in ensuring that employees of the SEC can maintain the utmost trust and transparency with the public. I agree that this will help avoid conflicts and appearance concerns with employee ownership of sector funds that invest in entities the SEC directly regulates, such as registered broker-dealers and investment advisers. It is vital that the SEC maintains its risk-based approach to mitigate any actual or perceived conflicts and appearance concerns. Secondly, I am concerned about the elimination of preclearance, reporting, and holding requirements for Permissible Diversified Investment Funds. While I understand that such funds pose little or no conflicts of interest for members and employees, I believe that the current pre-clearance and reporting requirements serve a crucial role in maintaining transparency and accountability. Removing these requirements could create a perception of decreased accountability and increase the potential for conflicts of interest to arise. I am particularly concerned about the potential impact on individual investors who rely on the SEC's oversight to protect their investments. The proposed amendments could make it more difficult for individual investors to assess whether SEC employees are acting in their best interests. It is essential that the SEC maintains rigorous reporting requirements to ensure that the public can trust that the agency is acting in their best interests. I am also concerned about the proposed changes to the reporting of purchases, sales, acquisitions, and dispositions of securities. While I appreciate the goal of enhancing consistency, timeliness, and accountability in reporting, I am concerned that authorizing the Commission to collect information automatically from the employee's brokerage or financial institution(s) through a third-party automated compliance application could compromise the privacy and security of employee financial information. I urge the SEC to ensure that appropriate safeguards are in place to protect employee privacy and prevent any potential misuse of the data collected. Finally, I support the clarification that the limitation on purchasing securities that are part of an initial public offering (IPO) until seven days after the IPO also applies to direct listings of securities. This clarification will help ensure that all SEC employees are aware of their obligations regarding IPOs and direct listings and will help prevent any potential conflicts of interest. In conclusion, I appreciate the SEC's efforts to enhance transparency, accountability, and compliance with the securities laws. However, I urge the SEC to carefully consider the potential impact of the proposed amendments on individual investors and to ensure that appropriate safeguards are in place to protect employee privacy and prevent any potential conflicts of interest. Thank you for your consideration of my comments. Sincerely, Jacob Gillmore