Jun. 26, 2023
Dear Members of the Securities and Exchange Commission, I am writing to express my support for amendments aimed at increasing transparency in stock ownership, and thereby providing a clearer view of market dynamics. I appreciate the efforts the SEC has already undertaken to identify major shareholders and potential conflicts of interest, which are crucial steps towards cultivating a more accountable financial system. To further these efforts, I encourage the adoption of a structured, machine-readable data language for filing Schedules 13D and 13G. This measure ensures efficient and standardized reporting, vital for enhancing transparency and facilitating timely reporting of short position changes. Rule S7-06-22, if correctly implemented, could bring much-needed visibility to hedge funds' short positions, preventing hidden accumulations and ensuring up-to-date market information, which is fundamental for a fair and free market. However, while I strongly support the expansion of transparency, I am concerned about the potential dilution of voting power for actual shareholders if cash settled derivatives owners are considered beneficial shareholders. To prevent unintended consequences and confusion, clear guidelines must be established. In this light, I am advocating for the protection of voting rights, ensuring that the votes of actual shareholders carry meaningful weight. Enhanced oversight through structured data enables better monitoring and identification of potential risks, which is essential for necessary regulatory actions and maintaining market integrity. Moreover, increased transparency and reporting requirements can act as a deterrent against coordinated actions aimed at suppressing stock prices. This ensures a level playing field for all market participants, fostering fair competition, and preventing unfair advantages for certain market participants, thus contributing to a more equitable market. I kindly request that the SEC prioritize these concerns and the protection of shareholder rights in the final rule. With the adoption of these suggestions, I believe that we can cultivate a more efficient and accountable financial system, ultimately benefiting investors and the overall health of the market. In conclusion, the enhancement of transparency, timely reporting, deterrence against manipulation, and a level playing field are critical for market integrity. It is essential that we urgently adopt and enforce these changes for the benefit of all investors and the health of the market at large. Thank you for your attention and for your commitment to fairness and transparency in our financial system. Sincerely, Matt Brady