Mar. 31, 2023
March 31, 2023 Thank you for giving me the opportunity to comment on a rule directly affecting us employees. Having said that, I vehemently disagree with the proposed rule's section that would require Commission workers and their families to report their financial information in an automated manner via a third-party vendor. We currently disclose our holdings and trades (mostly) manually, thus this method is unnecessary and puts employee privacy, identification, and finances (real money) at significant risk. The brokerages, which currently send email confirmations, can also email a group mailbox if the SEC needs to see our trades more rapidly (or we can forward). It is not worth it to use a risky automated approach, and a currently unknown entity to collect all of our financial data in order to make someone's job easier. Including a third-party provider not only increases the risk but also adds to the expense. How is this not a misuse of tax dollars? Anyone who is familiar with government contract s would realize that the expense of this is significantly greater than the benefit. Based on the similar rules that I found governing the industry, none compelled brokerage employees to only use an automated reporting process. The employee or their broker could opt to provide manual reports. I was hoping that there would be more details regarding how this reporting would work, however the proposed rule does not include that information. Odd considering that there is another proposed rule for the industry on Cybersecurity Risk management and Incident Disclosure. What is the SEC's plan given the number of breaches that federal agencies, including the SEC, have experienced? A SEC third-party contractor exposed my personal information and I was offered nothing more than credit monitoring, which I already had. I would think that the SEC would provide sufficient remedies to make the person whole (identity restoration, credit restoration, financial restoration and compensation, etc) sh ould this rule be put into effect. Otherwise, let's look into other possibilities for improving financial reporting. This comment was drafted and submitted on my own time, using my personal resources.