Jun. 28, 2023
Thanks for the opportunity to comment on this proposal. Please find my comments below. 1. I support more frequent and timely reporting and believe even 5 days is too long. If trade settlement is T+2, reporting requirements should match that. 2. I also support any obscured position or interest resulting from derivatives (like swaps) to be considered for the 5% threshold for reporting of ownership. 3. Would want explicit clarification that ownership or derivatives that are "long" a stock would not dilute the voting powers or rights of true beneficial owners who directly buy the stock. 4. In fact if I may, the fact that so many derivatives like the cash-settled equity swaps can be used to obscure rather than bring more transparency to the market begs the question: are they really NECESSARY for our financial markets? Or are they doing more harm than good? Do the niche needs they meet to give more "investment flexibility' really justify the risk of information disparity. I believe there are way too many financial instruments out there (and constantly being created), if the SEC and regulators can't keep up, I highly suggest you stop new ones being traded, and even roll back/ban/pause of existing ones until they can be scrutinized and regulated properly. 5. I think the same level of reporting requirements (if not more strict ones) should be imposed on short sellers and other who bets against companies. Especially so if these currently invisible short position holders may be public figures/experts/influencers/politicians who may use their might and network to sway market sentiment to their own advantage. Best regards PKBL - Household Investor.