Subject: s7-02-23: WebForm Comments from Eileen Parlow
From: Eileen Parlow
Affiliation: SEC Employee

Mar. 9, 2023



March 9, 2023

 I disagree with the proposal to require SEC employees to use an automated reporting system for compliance with employee ethics rules. Reasons:
1. Signing up and maintaining an automated reporting system is not less burdensome than the current system.
2.  Privacy concerns: For example, would the automated system redact irrelevant private information, such as the address and account number of the SEC employee, spouse, or dependent child?
3. Would the burden be on the SEC employee to stop the automated reporting when the dependent child becomes an adult, or when the SEC employee leaves the SEC?
4. Most importantly, would the automated reporting system be optional for SEC employees who prefer the current method of reporting?