Apr. 12, 2022
Gary Gensler, Chair SEC Headquarters 100 F Street, NE Washington, DC 20549 Vanessa A. Countryman Secretary, Securities and Exchange Commission 100 F Street NE Washington, DC 20549-1090 rule-comments@sec.gov Re: Modernization of Beneficial Ownership Reporting (File No: S7-06-22) Dear Chairman and Secretary: AFREF sent a comment supporting the SEC's proposals to modernize the reporting of beneficial ownership by including cash-settled derivatives in large position reports over Schedules 13D and 13G. Also the SEC should clarify its definition of who should constitute a "group" under the proposal as it should only apply to the sharing of material nonpublic information related to not yet disclosed large positions instead of efforts to improve the long-term corporate governance of companies. Full letter: https://protect2.fireeye.com/v1/url?k=31323334-50bba2bf-3132d782-4544474f5631-ccb87412a9bb1df7&q=1&e=24a0b833-a0bb-45a8-b4b2-3718a425a775&u=https%3A%2F%2Fourfinancialsecurity.org%2F2022%2F04%2Fletters-to-regulators-modernization-of-beneficial-ownership-reporting%2F Yours sincerely. Robert E. Rutkowski cc: Legislative Correspondence Team 1705 Longworth House Office Building Washington DC 20515 Office: Fax: 2527 Faxon Court Topeka, Kansas 66605-2086 P/F: E-mail: