Aug. 14, 2023
I appreciate the opportunity to comment on this proposed rule. I strongly disagree and reject Proposed Rule S7-06-22 as is presented. First thing that I take issue with is the need for revision to Rule 13d-1(a) filing deadline for the initial Schedule 13D to a "one-day" time-frame. This will streamline the accuracy of market data and allow greater transparency much closer to an instantaneous time-frame of real-time data for investors' decisions. The same thing goes for amending Rules 13d-1(b) and (d) to shorten the deadline for the initial Schedule 13G filing for Qualified Institutional Investors. This market operates at high-speeds, so there is no need for reporting delays; the technology currently exists to make all of this reporting happen easily and conveniently. Most likely these changes to one-day reporting requirements should be made in every instance across the entirety of Rules 13d. Again, 21st-century life requires 21st-century approaches and data flow. Most importantly, Rule 13d-3 SHOULD NOT have paragraph (e) added to it! There is no logical reason for a derivatives owner to have any influence on the corporate actions of any company when they have no long position in the company. By allowing voting rights and other unrecognized benefits granted by this paragraph to a newly-minted "beneficial owner" of cash-secured derivatives for the underlying asset, the opportunity then exists for market manipulators to direct the future of companies into ruin, all without ever having exposure to the company. There are far too many avenues of malicious exploitation introduced with giving beneficial rights to derivatives holders, even with the implication language being removed. This is a very bad idea to include this paragraph. The direction of this proposed rule needs further evaluation and consideration at this time and should definitely not be passed as is, especially with including the suspicious nature of deeming derivatives holders as beneficial owners. It is shameful that this part is even trying to be written into the bill. I am firmly AGAINST this proposed rule as it stands, especially Rule 13d-3(e). Please return this motion from whence it came, never to be seen again. Thank you for being courageous and doing the right things for all investors. The markets belong to 'The People' as a whole, not just one group with intention to harm. Juan B, Business Owner