Subject: S7-06-22: Webform Comments from Kevin O'Brien
From: Kevin O'Brien
Affiliation:

Aug. 2, 2023

Im conflicted on the rules and reporting changes
outlined in this proposal. What effect on the market will be as the
result of holders of certain cash-settled derivative securities
as beneficial owners of the reference equity securities?
It's not clear to me and many others as we don't understand
the reason for the change or the affect on the market.
In addition, the Proposed Amendments would clarify
and affirm the operation of the
beneficial ownership reporting rules as applied to two or more persons
that form a group
under the Securities Exchange Act of 1934, and provide new exemptions
to permit such
persons to communicate and consult with each other, jointly engage
issuers, and execute
certain transactions without being subject to regulation as a
group.
Why would people be able to form a group and not be subject to
regulation for certain transactions? Would this allow them to perform
transactions without being subjected to regulation? Wouldn't this
lead to less transparency?
As such, I do not support this proposed rule.