Jun. 26, 2023
Dear Securities and Exchange Commission, As a household investor and someone with experience in the world of programming, I write to express my thoughts on proposed rule S7-06-22. I've always found that clarity and precision, principles valued in both coding and investing, guide us toward better outcomes. The focus of this rule on modernizing beneficial ownership reporting and increasing transparency and fairness, mirrors these principles. Guarding Shareholder Rights: Beneficial ownership linked to the delivery of the underlying security is a key safeguard for shareholders like myself. It helps to preserve our voting power, an issue that resonates with me due to personal experiences with potential voting power dilution. Ensuring Fair and Equal Voting: Excluding derivative holders from the beneficial owners' list aligns with the idea of balanced and fair representation. It mitigates concerns I've had from my own investment experiences about potential dilution of voting power. Accurate Calculation of Ownership: The use of the delta concept for ownership calculation has my support. It promises an accurate representation of ownership, a commitment that I value in both my professional and investing experiences. Boosted Transparency: As someone who appreciates transparency, I applaud the requirement for hedge funds to reveal their short positions and activities. It offers investors like myself a clearer view of market dynamics. Prompt Reporting: Having up-to-date information is essential in any field, and the rule's requirement for timely reporting of short position changes aligns with this belief. This provision assists in preventing hidden accumulations and potential market manipulation. Heightened Oversight: The call for structured data for tracking ownership resonates with my background in programming. Enhanced oversight means regulatory bodies can better identify risks and take timely action, ensuring the market's integrity. Discouraging Market Manipulation: Transparency and robust reporting requirements, much like well-structured code, serve as deterrents against tactics that can manipulate stock prices. I welcome any initiative that leads to a more equitable playing field. Level Playing Field: The proposed rule's emphasis on providing all investors with relevant information fosters an environment of fair competition, which is something I value both as an investor and a programmer. Clear Guidelines: The importance of clear guidelines is a lesson I've learned from my coding experience. They help prevent confusion and unintended consequences, a principle I believe should be applied to market regulations. However, I express concern about the potential influence of special interests. As the SEC refines this rule, I urge that these influences be carefully considered to ensure the rule's integrity and its effectiveness for individual investors like myself. In conclusion, I appreciate the efforts made by the SEC in crafting rule S7-06-22. Its focus on transparency, prompt reporting, enhanced oversight, deterrence of manipulation, and creating a level playing field resonates with me. I encourage its timely adoption and diligent enforcement for the benefit of all investors and the overall health of the market. Sincerely, -- Faviann Di Tullio