Mar. 31, 2023
March 31, 2023 While I think exempting the diversified mutual funds from PTCS reporting is a wise move, the proposal to require employees to grant real time access to all accounts is a horrible and unnecessary idea. To be blunt, the SECs track record with data security including compromising our PTCS data at its outset frankly should be a disqualifier from even suggesting this proposal. Federal employees further had their sensitive background data compromised when OPM was hacked by the Chinese government several years ago as well. Most of the accounts to be reported under this rule are retirement accounts, including some from former employers, as well as 529 plans and are therefore very difficult to change account numbers or move if account data is compromised. Further, the rule description is ambiguously worded. Presumably it should scope out spouse and dependent accounts, as there is no basis for the agency to obtain real time access to these accounts. My son is currently taking a personal finance class in high school and his teacher is encouraging them to open a brokerage account to get the experience of investing in index funds. However, once this rule proposal came up, I strongly suggested he wait to see that this proposed rule was for sure rescinded or he turns 18 so that he doesn't take the chance on having his sensitive information compromised. You are causing hardships to more than just employees. The agency has not made the case that any of the limited numbers of past employee trading violations would have been prevented or more easily caught by this rule change. The number of violations is low to begin with and belies that such an invasive policy is completely unnecessary. The proposed overreach is not about prevention or enforcement, but clearly a just disrespect for privacy and sensitive information. Most employees redact out account number information when they submit their annual holdings as such data is not pertinent to the agency's oversight goals, but this rule proposal would expose all those details to multiple parties, which multiplies the chances such data will be compromised. That is a clear violation of the agency's own guidance on handling sensitive information: Don't collect it if you don't absolutely need it. And it is clearly not needed here. While this may make surveillance easier than combing through PDFs, laziness is not a sufficient reason to vio late our privacy and violate the agency's own data handling principles. The employees of the agency make daily sacrifices as public servants, including the various trading prohibitions. To propose such a rule is a slap in the face of their hard work and dedication. To pass it, is unconscionable and shows employees you don't value or respect them. It will drive employees to unnecessarily close out of securities accounts and/or roll them into the TSP which has fewer investment options to keep their information from being compromised. This will not aid in recruiting new employees, and will lead to lower FEVS scores.