Subject: File No. S7-06-22
From: Samuel Ryan
Affiliation: Senior Battery Test Engineer, ESS Inc.

February 18, 2022

This is a long overdue modernization. The current state of derivative reporting creates, at a minimum, the appearance of impropriety for market makers and investors that cannot be resolved without comprehensive transparency. Whether market makers are abusing the trust they've been given is immaterial to the positive value of this rule change.