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.