Jun. 28, 2023
Dear Securities and Exchange Commission, I am writing to offer some essential considerations regarding the Proposed Rule (S7-06-22) recently introduced by the Securities and Exchange Commission (SEC), which focuses on the modernization of beneficial ownership reporting. Firstly, I think including cash-settled equity swap under beneficial ownership creates a fairer market and ensures transparency. Derivatives and/or Swaps impact the ownership of certain assets significantly. Concealed positions, owned by institutional funds, private firms, and corporations create an unfair advantage and add to the many ways household investors are deceived. Cash-settles equity swaps do not transfer voting rights or investment powers. The proposed rule with improvements establishes trust, and therefore advocates for transparency within the financial markets. I appreciate the SEC’s efforts to modernize beneficial ownership reporting, however I think implementing further improvements are necessary to maintain the integrity of the market. Thank you for your consideration and reading my comments. Sincerely, Matt Hildebrand