Aug. 13, 2023
I do not support this proposal as it is written. My fear is not in the SECs attempt to "modernize the rules governing beneficial ownership reporting" but in changing the definition of a beneficial owner to include "certain derivitave holders" which could mean (if I am not mistaken) counterfeit share traders via the evil liquidity fairy that perverts our markets by trading in dark pools and who avoids market price discovery as it should be. You must find another way to enforce and encourage reporting of ALL types of market positions. As far as I understand the proposal, shareholders might be further disenfranchised as asset holders and possibly even lose their voice in shareholder meetings/votes where company direction is at stake. Short sellers would LOVE to have a vote in those meetings for obvious reasons. A quick look at the companies who fell in the wake of Boston Consulting Group infiltrations might change your thoughts on the importance of this as well. Thank you for your total considerations and hard work. Adam N.S. P.s. I haven't forgotten how the DTCC commited international securities fraud during the Gamestop stock split by "accidentally" miscategorizing them and adding more shares to the trading pool from nothing. Perhaps this didn't happen. It would be nice to have the tools needed to find these things out or maybe FOIA requests would do the trick. Or perhaps even your rules don't matter and I should take my money elsewhere.