Jun. 28, 2023
Dear SEC, I write to you in support of the proposed changes to the beneficial ownership reporting requirements, particularly the reduction of the disclosure deadline from 10 days to 2 days. The current rules, unchanged since 1968, allow institutional investors to accumulate significant shares without the knowledge of other market participants, creating a significant information asymmetry. Also, I strongly support the proposed derivative disclosure requirements. Cash-settled derivatives, despite not conferring beneficial ownership under current definitions, often allow their holders to exert significant influence over companies. Recognizing these derivatives in disclosure requirements will increase market transparency. However, I urge the SEC to clearly state that the holders of these derivatives, despite being considered beneficial owners under this rule, will not have any change to their voting rights or investment powers. This clarification is important to maintain the clear distinction between economic interests and governance rights in a company. I appreciate the SEC's efforts to modernize the beneficial ownership reporting requirements and believe that these proposed changes will significantly enhance market transparency and fairness. Thank you for your attention to these important issues. Sincerely, Keith Hanshaw (HNDip)