June 26, 2023
To whom it may concern,
It has VERY recently come to my attention that if this proposal were \"to deem holders of certain cash-settled derivative securities as beneficial owners of the reference covered class\", that this would, in reality, grant holders of those certain cash-settled derivative securities voting rights within said companies from which those securities were issued.
While overall, this proposal appears to be sound with its intentions to improve requirements for reporting of derivative positions, it absolutely cannot be understated how allowing anyone without actual possession of the securities in question to have the same rights as those of actual holders of said securities including voting rights, would be absolutely detrimental, if not completely destructive to actual holders of said securities by eroding their control over a company.
In light of this, I simply urge the commission to hold this proposal for consideration until the above situation can be both clarified and rectified so as not to be detrimental, financially or otherwise, to any holders of securities.
The shares outstanding of a company must be respected, and the holders of said shares must also have their rights respected for the US financial system to maintain any level of trust or integrity. Those rights can not, nor should not be diluted or given to others without actual ownership.