Mar. 29, 2023
March 29, 2023 As an SEC employee, I am extremely troubled by one particular portion of this proposed rule. Specifically the part that seeks to (3) enhance consistency, timeliness, and accountability in employee reporting of purchase, sales, acquisitions, and dispositions of securities by authorizing the Commission to collect such information automatically from the employees brokerage or financial institution(s) through a third-party automated compliance application... (emphasis added). To require employees to allow DIRECT access by a third-party to such sensitive information is outrageous. To be clear, under the current system, pre-clearance of transactions is completed via an internal system that has worked well and is not disproportionately burdensome for both SEC employees and the (OEC). Eliminating pre-clearance and quarterly reporting in return for handing over access to personal account information is no prize. In fact, it is insulting to think that SEC employees would believe that giving direct access to our accounts to anyone is in any way a reasonable thing. We already have some of the strictest compliance requirements in the government. They admit that the current process has been successful yet provide the thin reasoning that this process is burdensome and presents the opportunity for human error. These are not strong reasons to shift employees to this highly intrusive requirement. The current system is not in any way broken or insufficient. Farming out any aspect of compliance to a third-party is absolutely NOT the way to go. Creating yet another avenue of personal exposure is unacceptable. The OEC states it is aware that a number of private corporations have shifted to automated software systems that provide direct notification of securities transactions from an individuals broker or other financial institution. Again, not a compelling reason to expose employees to unwarranted and unnecessary intrusion. Private corporations conduct their business in any number of ways that are favorable and/or unfavorable to their employees. Just because you can, doesnt mean you should. The agency doesnt do many things that the private sector does. To use this as reasoning on any level is disingenuous. SEC employees have a sacred right to privacy. Making it mandatory that a third-party have direct access to our accounts invades this privacy in a way that cannot be undone. Further, If anything were to happen as a result of this unwarranted and unnecessary intrusion, they would just throw credit monitoring services at us for some period of time and think their hands were clean (as with other breaches). It must be noted that credit monitoring services are limited and after-the-fact of any breach. Additionally, employees must re-certify regularly to continue to receive the credit monitoring services - which creates a burden on the employee. For these reasons, I am adamantly against the portion of the rule that requires employees to provide direct access to any accounts.