June 26, 2023
Hello, I am commenting on proposal S7-06-22. Generally speaking I support the proposal, I think it helps adds some much needed transparency to our capital markets, especially in regards to increased reporting of assets. I do think that the changes regarding the definition of a group are somewhat vague and may benefit from more definitive wording. I also am not sure if I support the changes regarding section 13d-3 as frankly I cannot tell fully based on the wording what rights would be held by cash settled securities holders who would be deemed beneficial owners under the new changes, I would like to see some changes to the wording to more obviously clarify the scope of \"beneficial ownership\" in this case. If the changes give people such as options contract holders rights that can effect the company/stock issuer or their business practices in the same way that a standard stock holder could, then I do not support this change as often times options contracts are often either: naked, are never executed, or used to hedge bets, and as such do not intend to ever purchase stock. I believe that could be a problem as it would give the capital markets too much power over companies in a way that could work to the companies detriment, even though capital markets are there more so to aid companies. On the other hand if the proposed changes to beneficial owners would not work in the way stated above, then I do support it, Thank you for your time I apologize for my lack of understanding, I hope you have a wonderful rest of your day/night.