Subject: Comment on SEC Rule Proposal S7-06-22 -:Modernization of Beneficial Ownership Reporting & Support for Ensuring Transparency & Fairness in the Market
From: Zach N/A
Affiliation:

Jun. 26, 2023

Dear SEC, 


Additional comments in regards to Rule Proposal S7-06-22- 


I have support for reporting deadlines for Schedule 13D and 13G filings. 


Clarification: Derivatives don't immediately convey ownership so beneficial ownership should be granted only when the underlying is delivered otherwise shareholder rights are diluted by derivatives holders who may never take ownership of the underlying security. 


I Reject the amendments to Rule 13d-3 to deem holders of certain cash-settled derivative securities as beneficial owners of the reference covered class. 



Request: Extend the comment period for either the entire proposal or at least for the amendments to Rule 13d-3 for deeming holders of certain cash-settled derivative securities as beneficial owners of the reference covered class. 

Thank you!