Aug. 15, 2023
Appreciate the opportunity to comment on S7-06-22, "Modernization of Beneficial Ownership Reporting," as a retail investor. Requesting an extension for public review due to heightened interest. Support amendments for improved filing deadlines and disclosures, aligning with technological advancements. Strongly oppose Rule 13d-3 amendments for cash-settled derivatives. Concerned about unintended consequences, dilution of shareholder rights, and complexity in the voting process. Derivatives should not confer ownership benefits without direct voting rights. Against Rule 13d-3(e) amendment for counting long positions only, disadvantaging retail investors. Reject conferring beneficial ownership rights to derivatives holders. Transparency through reporting suffices. Sympathetic to controlling influence concerns, but support separate reporting for derivatives positions. Reject conferring beneficial ownership to derivatives holders. Transparency avoids unnecessary complications. This comment doesn't cover all aspects, but if extension isn't possible, urge rejecting the proposal due to risks outweighing benefits in amending Rule 13(d)-3. Thanks for considering retail investor input