Subject: Comment on SEC Rule Proposal S7-06-22 - Modernization of Beneficial Ownership Reporting and Support for Ensuring Transparency and Fairness in the MarketDear Securities and Exchange Commission, I am writing to provide my comments for the proposed rule S7-06-22, which aims to modernize beneficial ownership reporting and enhance transparency and fairness in our financial markets. Comments and requests are as followed, Protecting Shareholder Rights: By granting beneficial ownership only when the underlying security is delivered, the proposed rule can safeguard the interests of existing shareholders and maintains their voting power. This protection is essential to prevent dilution and ensure fair representation. Ensuring Fair and Equal Voting: Opposing the inclusion of derivative holders as beneficial owners maintains fair and equal voting rights for directly registered shareholders. It prevents undue influence from derivative holders who may not have actual ownership of the underlying
From: Brandon Pearce
Affiliation:

Jun. 26, 2023