Mar. 13, 2023
March 13, 2023 If section II.B of the proposed standards eliminates some reporting requirements, section II.C would only need to apply to employee accounts which contain reportable funds. So, for example, employees who do not possess reportable funds would only need to enroll in automated reporting if they subsequently purchased such funds. Therefore, if the automated reporting requirement in section II.C is enacted, the language of the proposal should be updated to make it clear that it only applies if employees hold reportable funds. Employees who do not hold such funds do not need to enroll in automated third party reporting, and employees who divest themselves of all such funds can withdraw from the automated reporting program. The requirement for employees to enroll in an automated reporting program can actually be eliminated altogether, because the prohibition of holding certain sector funds in section II.A and the reduction of the reporting requirements in Section II.B both substantially reduce the need. It does not make sense to both reduce reporting requirements AND make them automated. Either the reporting requirements should be reduced, OR they should be made automatic. Reduction of the reporting requirements will necessarily reduce administrative burden, while development of an automated reporting system will, at least initially, increase it. The need for automated systems typically arises when there are large amounts of data and the volume of data is expected to increase. In this case, the amount of data is expected to decrease due to the elimination of reporting requirements on some funds and prohibition of holding others. The administrative burden required to acquire, develop, secure, and monitor an automated reporting solution is not likely to be justified in light of the reduced reporting requirements. Further, as echoed in other comments, imposition of a third party system increases the risk of sensitive data disclosure and imposes an additional administrative burden when it does occur.