Subject: Comment for File No. S7-6-22
From: Spencer Neukam
Affiliation:

Aug. 21, 2023

Hello, 


I want 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 emphatically disagree with the notion that derivatives holders should have full beneficial rights of ownership, especially in regards 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 is not good for anyone, and distorts true shareholder ownership and say within a company. Shareholders are invested in companies and aligned with company interest. Shareholders alone should have beneficial ownership rights and voting influence in their companies. 


Thank you for your consideration. 


Spencer Neukam