Subject: RE: S7-06-22 Modernization of Beneficial Ownership Reporting
From: Gina Chamberlain
Affiliation:

Jun. 26, 2023

To Whom It May Concern:

I’m concerned about the potential dilution of voting power of actual shareholders if cash settled derivatives owners are considered beneficial shareholders.

The protection of actual shareholders with full voting rights remains important. Holders of derivatives should not have voting rights as they indirectly participate and thus indirectly support the company that they are invested in.

Please ensure that there is full transparency, and clear definitions of voting and rights.

Holding a share, although intangible, is property that belongs directly to a person who has invested their own money. Just as those who own mbs and cmbs don’t have direct ownership of real property and hence no rights in the ultimate property, so too derivatives holders of equities should not have direct voting rights.

Thank you for your consideration,

Gina C.

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