Aug. 14, 2023
Subject: S7-6-22 I do not support this rule however appreciate a shortened reporting window. If you want my support for this rule, you need to remove the derivative rights portion as there is no reason for a derivative holder to receive control of something they are BORROWING. Also, reporting should be immediate with 0 exceptions. Institutions commenting on this rule in favor are by default breaching their fiduciary responsibilities as this will impact their client base negatively in the long run. -Michael Gilbert