Aug. 16, 2023
I am writing to express my vehement opposition to the proposed SEC Regulation S7-6-22. As a concerned investor and advocate for maintaining the integrity of our financial markets, I firmly believe that this proposal, if implemented, would have detrimental consequences for the very essence of long-term investment and the stability of companies. The current regulatory framework in place provides a critical safeguard, ensuring that the locus of control over a company's decisions remains in the hands of dedicated long-term investors. These individuals are vested not only in the financial success of the company but also in its values and long-term growth trajectory. The comprehensive understanding they possess of the full spectrum of risks associated with a security is a justifiable cost in exchange for the privilege of contributing to a company's accomplishments and influencing decisions that impact their investments. My steadfast opposition to this proposal stems from the recognition that the existing system grants authentic investors, genuinely invested in a company's prosperity, a proportionate influence in decision-making processes. Moreover, it empowers companies to discern the depth of commitment and support exhibited by individual investors. This transparency is instrumental in fostering alignment between a company's vision, objectives, and the viewpoints of its stakeholders. Reiterating my reservations, I strongly object to this proposal due to its potential ramifications. Restricting these rights solely to initial securities holders equips companies with invaluable insights into the principles and perspectives of investors who attach non-financial worth to their association with the business. This dynamic bolsters the capacity of companies to effectively recognize, address, and reward stakeholders whose viewpoints resonate with the company's overarching mission and values. Consequently, this approach facilitates a more assured alignment with the aspirations and intentions of investors who seek to contribute to the holistic advancement of the company, transcending mere financial gains. Adopting a more critical stance, it is conceivable that granting external entities the opportunity to secure these rights, possibly through derivative instruments at a fraction of the cost borne by traditional investors, could lead to a distorted representation in decision-making processes. Such a scenario risks marginalizing the voices of dedicated long-term investors who bear the brunt of consequences arising from resultant decisions. In light of these concerns, I implore the SEC to reconsider and withdraw Proposal S7-6-22. The preservation of the current safeguards is vital for maintaining the integrity of our financial markets and safeguarding the principles that underpin long-term investment. Thank you for your attention to this matter. I trust that the SEC will carefully consider the implications of this proposal and make a decision that aligns with the best interests of both investors and the stability of the companies in which they invest. Sincerely, Ian