Subject: Release Nos. 33-11180; 34-97405; File no. S7-06-22 Reopening of Comment Period for Modernization of Beneficial Ownership Reporting
From: Matt Waterman
Affiliation:

Aug. 01, 2023

Hello,

I wanted to voice my concern about the wording in File No. S7-06-22. Where it says, starting in the 7nth line of the summary, “ The Proposed Amendments also would deem holders of certain cash-settled derivative securities as beneficial owners of the reference equity securities.” I wanted to emphatically disagree with the notion that derivatives holders should have full beneficial rights of ownership, especially in regards to company voting. If derivatives holders are allowed voting influence it would allow players to come in and have levered influence over a company and that isn’t good for anyone. Shareholders are invested in companies and aligned with the companies interests. Shareholders alone should have beneficial ownership rights and voting influence in their companies. Thanks for your consideration.

Matthew,