Subject: File No. S7-12-22
From: Denys Petrina

March 28, 2022

I am against this proposed rule for two reasons:

1. In my view, any rule that requires more than 5 typed pages is automatically too complex and implementation should be delayed until it can be simplified

2. As explained in the background given for the rule, this rule has been called-for by a group of investors who believe companies are \"not reporting enough\" while there are a number of different standards already in use. I believe the government should remain neutral in these disagreements while the markets themselves should flesh-out/refine which standard is the best.