Mar. 30, 2023
March 30, 2023 Relating to \"Automated Reporting of Purchases, Sales, Acquisitions, and Dispositions of Securities,\" as an SEC employee, I do not agree with the proposal due to PII and cybersecurity vulnerabilities that occurs on a regular basis in both the private and federal sector. What I find troubling is that in the proposal, it states it is successful with respect to SEC employees submitting the required documentations relating to transitions of securities. It gave very thin non-convincing reasons as to why the system need to be automated. They did not provide clear and convincing evidence as to why automated system is better. Nor did they offer any concrete data surrounding the number of \"human error\" and how burdensome OEC is, such as processing time. Based on my experience, my submissions to OEC has been processed promptly without any issues. If OEC is burdensome with doing this tasks, it could hire additional staff for OEC. I am gravely concern with the prospect of allowing OEC unfettered access to our financial accounts through a third-party. If the Commission insist on proceeding, then they should allow us to opt out of the automated system and upload our financial documents as what we have always done so far. I am also concerned with the potential additional burden on SEC staff related to this because it will impact recruitment and retention when prospective candidates discovered they have to give unfettered access to their financial accounts to keep their job. As far as I am aware, no other federal financial agency, such as CFPB, FDIC, OCC, Treasury, requires this kind of infringement on our privacy rights with respect to our individual financial records, including PII.