June 20, 2023
Dear members of the Securities and Exchange Commission,
I wanted to express my sincere appreciation for reopening the comment period on the proposal for the \"Modernization of Beneficial Ownership Reporting.\" This initiative holds tremendous potential to enhance efficiency, transparency, and collaboration in the realm of beneficial ownership reporting. The Proposed Amendments, including modernizing filing deadlines, recognizing cash-settled derivative securities as beneficial owners, and clarifying group formation rules, reflect a forward-thinking approach that addresses the evolving needs of market participants. The requirement for structured, machine-readable data language in filing Schedules 13D and 13G is a commendable step toward leveraging technology for improved data accessibility. Thank you for your commitment to inclusive governance and for providing interested individuals with the opportunity to contribute their insights and perspectives to this crucial conversation.
Sincerely,
Michael Wichkoski