Subject: S7-6-22
From: Tom Zhang
Affiliation:

Aug. 10, 2023

Hi there 

I wanted to voice my concern about the wording inFile No. S7-06-22. Where it says, starting in the 7nth line of the summary, “ The ProposedAmendments 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. 



Tom