June 27, 2023
I'm a household investor with a family to take care of and a grueling manual labor job that leaves me pretty well exhausted at the end of every day. That being said I did my best to read over what is being proposed and attempt to make up my mind on how I feel about it. Overall its pretty damn confusing and not always overly clear. It may be beneficial to further extend the comment period to give regular working people that make this country function more time understand it. Not everyone can afford a team of dedicate professionals to scour these things night and day to ensure everything works out in our favor. Regardless here's my thoughts on this proposal at this moment...
I have overall mixed thoughts on it based on my understanding of it. To be more specific...
I SUPPORT the increased reporting requirements and transparency. However, I don't feel they are sufficiently strict as a whole. I noticed that it seems heavily focused on the reporting of long positions, but didn't seem to cover the reporting of short positions. I don't think short positions should be allowed to be hidden.
This also seems to, as usual, rely on \"self reporting\" which is great as long as the people doing the reporting are honest and upstanding, but we're talking about Wall Street which is dominated by criminals that couldn't give a rats ass about anyone they deem beneath them, which is everyone. But hell, why would they? The only punishments they receive are a slap on the wrist, maybe a harsh finger wag, no need to admit guilt, no jail time, and at worst a minimal cost of doing business \"fine\".
I am VERY concerned about the way that holders of derivatives and options can be \"deemed\" as \"beneficial owners\". I'm concerned that this could open up some loopholes that will allow abuse down the road. This definitely needs to be heavily clarified as to EXACTLY what this allows and in exactly which cases as well as what it DOES NOT allow or entail.
The biggest concern I have with this is that it gives the impression that this could allow holders of derivatives to have voting rights. I certainly hope that isn't the case and if it is or could in any way allow such a thing it most definitely should not
Personally, I think that only investors holding an actual (not just \"mismarked as\") long position should be eligible for voting rights. In general I believe only investors with a personal, direct, and vested interest in a company SUCCEEDING should be eligible for voting rights.
Given the amount of abuse and manipulation already present in the voting process, such as why we need \"vote trimming\" in the first place, I truly think what ultimately needs to be done is to have stock share be serialized. By serialized I mean that they should have an individually trackable serial number or other form of identifier, perhaps even using blockchain technology. If individual shares were non-fungible and it was possible to always know exactly who owned it and where it was \"located\" in the stock market system that would help to cut out a vast amount of the criminal manipulation and \"miss-marking\" that financial institutions regularly use.
In closing, I support the reporting but want it more strict and any chance of voting rights abuse or any other abuse by way of deeming derivatives holders as beneficial owners needs to be IRONCLAD in its implementation and enforcement to prevent abuse.
This is all that I can think of to comment on off the top of my head. I'd love to say more but I simply don't have the time as I have to leave so I'm not late for my \"pandemic essential\" job that wrecks my body, wastes my time and potential, and doesn't even pay a livable wage. Gotta love America... at least the criminals are well paid.
Sincerely,
A household investor and typical American wage slave