Aug. 10, 2023
Dear Securities and Exchange Commission, I have already commented on this proposed rule with my criticisms and supporting arguments. However, as time has elapsed, it has become clear to me that this rule needs to be revised and republished. First, I want to say I support the increased reporting requirements portion of the bill. I would also like to change this to day-of reporting or "same-day" reporting. We have the means to do so and it would further bolster transparency and real-time accuracy of data. However, this is a good step. However, I am very concerned that derivative positions receive beneficial ownership rights. This could come at the cost of traditional shareholders and those who use derivatives to manipulate and abuse stocks and the overall market. Shifting the meaning of beneficial ownership to institutions that don't have to allocate the proper amount of capital is not right. I believe this 'modernization' will facilitate and perpetuate naked short selling and insider trading. Every short and derivatives position should be reported and transparent. I like that the rule makes that a point. However cash settled derivatives should not receive these rights to the underlying security. I suggest this bill is reworked to increase transparency and accountability against derivatives fraud and naked short selling. This rule needs to work in favor of the retail investor. Thank you for your time. Regards, Sarabjit Singh