Subject: File No. S7-11-15
From: John A Olagues, Jr.
Affiliation: Truth In Options

August 10, 2015

Below is part of the definition of "Beneficial Owner"

240.13d-3 Determination of beneficial owner.

(a) For the purposes of sections 13(d) and 13(g) of the Act a beneficial owner of a security includes any person who, directly or indirectly, through any contract, arrangement, understanding, relationship, or otherwise has or shares:

(1) Voting power which includes the power to vote, or to direct the voting of, such security and/or,
(2) Investment power which includes the power to dispose, or to direct the disposition of, such security.

Part a) (2) which includes the power to dispose or to direct the disposition of such security

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Assume a person calls and puts. Does the ownership of the calls add to the person's beneficial owner ship?
Suppose that the puts are exercised, does that reduce the beneficial ownership?
Suppose instead of owning calls, the person owns stock and puts. Suppose that the puts are exercised. Does the exercise reduce the beneficial ownership of the stock position immediately