Subject: Comment for S7-6-22
From: David Choate
Affiliation:

Aug. 2, 2023

I DO NOT SUPPORT THIS PROPOSAL AS IT IS WRITTEN; AND FULLY BELIEVE THIS PROPOSAL WITH THE INCLUSION OF THE BENEFICIAL RIGHTS AMENDMENT and INSIDER TRADING ALLOWANCE, FACILITATES FRAUD AND ABUSE IN OUR MARKET. It will also increase the already unfair playing field advantage that institutions enjoy on a daily basis. It is beautiful however, to see the , QUID-PRO-QUO document. If this proposal passes, I would expect a wave of retail investors finding legal representation to fight back amongst other avenues (removal from markets, educating the masses on the inherent corruption, etc.). Stop trying to make the market UNFAIR for Retail participants and pretending we are too dumb to understand what you are actually doing and saying.
I fully support increased reporting requirements and would much rather see SAME DAY REPORTING as the technology to do so is available and it only makes sense to facilitate a free and fair market that is transparent. That said, I need to emphatically state that this proposal needs to be reworked completely. My suggestion is the removal of “ALLOWED INSIDER TRADING” and the removal of “Beneficial ownership requirements”. The fact that there is an attempt in this proposal to fleece beneficial holders of their rights; and provide them to an institution that has elected to pay a fraction of what the actual cost of ownership in a company at 5% or higher would be; is inconceivable. The rights investors benefit from which is really the only reason to invest in the market as an investor, are under attack by this exact proposal. This proposal WILL FACILITATE FRAUD AND ABUSE of investors and the market in general.

David Choate Supplier Manager T: +1 303-645-8750 E: David.Choate@arrow.com 
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