Jun. 26, 2023
I urge the Securities and Exchange Commission (SEC) to address these concerns and prioritize the protection of shareholder rights in the final rule. The adoption and enforcement of this rule are urgently needed to enhance transparency, ensure fair competition, and maintain market integrity. These changes will contribute to a more efficient and accountable financial system, benefiting investors and the overall health of the market. I appreciate the efforts made by the SEC to identify major shareholders and potential conflicts of interest, promoting a more accountable financial system. By adopting structured, machine-readable data language for filing Schedules 13D and 13G, the SEC can ensure efficient and standardized reporting, further enhancing transparency. The proposed rule, S7-06-22, has the potential to bring much-needed transparency to hedge funds' short positions, which is essential for a fair and free market. However, careful implementation is crucial to avoid unintended consequences, such as the dilution of voting power for actual shareholders if cash settled derivatives owners are considered beneficial shareholders. Clear guidelines must be provided to prevent confusion and ensure that the votes of actual shareholders carry meaningful weight. Timely reporting of short position changes is necessary to prevent hidden accumulations and ensure that market information remains up-to-date. Enhanced oversight through structured data enables better monitoring and identification of potential risks, leading to necessary regulatory actions and maintaining market integrity. Transparency and reporting requirements act as a deterrent against coordinated actions aimed at suppressing stock prices, ensuring a level playing field for all market participants. The adoption of this rule fosters fair competition, prevents unfair advantages for specific market participants, and contributes to a more level and equitable market. In conclusion, increased transparency, timely reporting, enhanced oversight, deterrence against manipulation, and a level playing field are crucial for market integrity. I urge the SEC to prioritize these aspects in the final rule for the benefit of all investors and the overall health of the market. Thank you for considering my comments. Yours financially, Ian Cannonhammer