Subject: Comment on S7-06-22
From: Derek Weiss
Affiliation:

Aug. 14, 2023

I do not support this amendment as written. I do not believe a holder of cash-settled derivative securities should be deemed a beneficial owner of a security. The process is so easy that I can't imagine a need for a mechanism that infinitely complicates the functioning of our markets. If you would like to be an owner of a security, you purchase it. 


Thank you, 
Derek Weiss