Jun. 26, 2023
Dear Rule Committee, Dear Ms Countryman, Please consider my concerns and suggestions regarding proposed rule S7-06-22. Beneficial ownership should only be granted when the underlying security is delivered. This serves to protect shareholders and to prevent dilution. I am deeply concerned about the inclusion of derivative holders as beneficial owners. Derivative holders who may not have actual ownership of the underlying securities may influence voting outcomes in an unfair way. Thus I encourage to maintain fair and equal voting rights to registered shareholders. I concur with the proposed rule insofar as hedge funds to disclose their short positions and activities. It ensures that relevant information is accessible to all market participants. Prompt reporting of short position changes prevents the accumulation of hidden short positions, reducing the potential for market manipulation. This furthers transparency and provides investors with a clearer picture of the market. Overall, the proposed rule should focus on and grant protection of shareholder rights, ensuring fair and equal voting, accurate calculation of ownership, increased transparency, timely reporting and thus facilitate integrity and fairness of financial markets. Thank you very much. Sincerely, J.S.