Subject: S7-06-22
From: Zach Brown
Affiliation:

Jun. 25, 2023

Hello my name is Zachary Brown, I am a Financial Advisor and have a Bachelor's Degree in Finance from the Eastern Washington University. 


I am deeply concerned about SEC Rule Proposal S7-06-22. The allowing of "Long" Derivatives to be given the rights to vote as beneficial owners of the underlying security could lead to the gross abuse of large institutions to over-vote for shareholder meetings. There have been numerus examples of institutions mismarking Short Derivatives i.e Selling Call as Longs (Goldman Sachs and others). 


If the largest institutions have free reign to self-report their derivative positions and then able to vote with positions that cost less than actual shares. Derivatives have an exponential amount of control over shares in terms of purchasing power versus regular share ownership and will lead to an extremely unbalanced voting power over actual shareholders with REAL stakes in the company. There are already issues with over-voting on securities and ownership of phantom shares the passing of this rule will completely undermine the integrity of the US Stock Market and erode the trust the American population has that we have free market that is continuing to dwindle. 


Thanks for reading and please realize the amount of damage this rule if passed will have, sooner rather than later. 


Zachary Brown