Jul. 20, 2023
Thank you for taking the time to accept comments on this very important issue regarding our financial markets. I'll keep this brief. I am writing to express my opposition to the initiative in proposed rule S7-06-22 that would grant voting rights to derivative holders. While I understand that the goal of this initiative is to increase shareholder participation and engagement, I believe it could have significant negative consequences for the integrity of the proxy voting process and the interests of shareholders. For one, derivatives aren't real shares that's why they call them derivatives. Derivatives are an instrument of the underlying (i.e. the stock), granting voting rights to derivative holders could lead to potentially harmful conflicts of interest. On top of the fact that derivative contracts are often used for speculative purposes and do not necessarily represent a direct ownership stake in the underlying corporation. Allowing derivative holders to vote on corporate matters could give them undue influence over decisions that affect the company and its shareholders. Furthermore, derivative holders may not have the same long-term interests as traditional shareholders who invest directly in the company. That is something I think we can all easily agree on. Finally, granting voting rights to derivative holders could significantly complicate the proxy voting process and make it more difficult for shareholders to exercise their rights. It could also be difficult to accurately determine who has voting rights and how many votes each holder should receive. As such, I urge the SEC to reconsider this initiative and work towards alternative solutions that promote shareholder engagement while maintaining the integrity of the proxy voting process and protecting the interests of all shareholders. Thank you for your time and consideration. Sincerely, Taylor Norris