Mar. 20, 2023
March 20, 2023 The SEC attempts to cram multiple proposals into the Supplemental Standards of Ethical Conduct for Members and Employees of the Securities and Exchange Commission. This is confusing to both the reader and the commenter. Nonetheless, I write to comment on the portion of the proposal that concerns Automated Reporting. I am a spouse of an SEC employee. I am also an attorney. The proposed rule seeks to require me to give an undisclosed third-party direct access to my financial accounts. To justify this misguided intrusion on my privacy and security, the SEC cites only Section 107 of the Ethics in Government Act of 1978 and 5 CFR 2634.103. Neither appears to give the SEC the broad reach it seeks. This proposal is poorly conceived and should be rejected before it is approved. If approved, the SEC should be prepared to litigate the issue.