Subject: Comment Letter for S7-06-22 Modernization of Beneficial Ownership Reporting
From: Lars Wohlfahrt
Affiliation:

Jun. 27, 2023

Dear Sir/Madam,

The proposal put forth by the SEC to reduce the reporting window is a
notable advancement for the securities markets. Nevertheless, I strongly
encourage the Commission to give careful thought to implementing a
reporting deadline based on a single business day.

As per the existing regulations set by the SEC, investors are
acknowledged as beneficial owners of a security when they possess voting
and/or investment authority over said security. It is important to note
that the definition of beneficial ownership does not encompass
individuals or entities with solely an economic stake in a security.
According to the Proposed Rule by the SEC, it is suggested that the
holder of this particular type of swap should incorporate the underlying
reference shares when determining whether the institutional investor has
surpassed the 5% ownership threshold. I strongly support this aspect of
the Proposed Rule.