Subject: File No. s7-06-22
From: Michael Holman

June 26, 2023

Allowing derivatives holders to be counted as beneficial owners of the underlying security is a horrible idea and the SEC knows it. This would allow derivatives holders voting rights and clearly favors big money and market makers while crushing retail. Whats to stop a bad actor market maker hedge fund from purchasing thousands of cheap contracts and using their voting rights to destroy companies they may be short on? Allowing this rule would show the world that the United States financial system is rigged and would undoubtedly make us even more of a laughing stock.