Mar. 10, 2023
March 10, 2023 The proposed reporting requirements pose an unreasonable risk to the privacy and data security of SEC personnel financial information. The proposal was silent about the standards, safeguards, and liability that would be required by or imposed on the third-party administrator and how those standards would be monitored and tested by additional independent overseers. Moreover, as the reporting requirements would remain the obligation of SEC staff, the proposed rule would add significant new costs and risks to the reporting process, thereby seemingly offsetting any theoretical administrative benefit to the agency. Finally, the proposal lacked a meaningful risk analysis of the current reporting system and the need for additional and costly administrative burdens and risks.