Subject: Comment on SEC proposal S7-6-22
From: Shenna Lehmer
Affiliation:

Aug. 17, 2023

Dear Sir or Madam: 




I wanted to voice my concern about the wording in file No. S7-06-22. 


Where it says, starting in the 7th line of the summary, “ The Proposed Amendments also would deem holders of certain 
cash-settled derivative securities as beneficial owners of the reference equity securities.” I wanted to emphatically disagree with the notion that derivatives holders should have full beneficial rights of ownership, especially in regard to company voting. 


If derivatives holders are allowed voting influence it would allow players to come in and have levered influence over a company and that isn’t good for anyone. Shareholders are invested in companies and aligned with the companies' interests. 


Shareholders alone should have beneficial ownership rights and voting influence in their companies. 


Thanks for your consideration. 


Sincerely, 


Shenna Lehmer