Jun. 25, 2023
Dear SEC: Please consider my comments: 1). Reporting material changes in derivative ownership is good. Derivatives can influence stock prices and should in fact be 100% reported in real-time with ongoing transparency. A block-chain technology could accomplish this. 2). The only owners of a share should be the shareholders. Anything else is not rational. Derivative owners are not shareholders. They are involved in shares but should not be deemed Beneficial Shareholders and should not be allowed to vote. This regulation conflates on the definition of Beneficial Ownership in order to set limits of purchases that require disclosure and share ownership. Pull those two apart. Anyone who owns derivatives that have similar influence on share price as beneficial ownership must report it. They do not become beneficial owners but their influence is properly documented. This rule needs to be fundamentally reworked to protect the interests of shareholders and provide transparency on derivative influence on those primary shareholders. I cannot support this rule as written. Daryll Fogal.