Subject: File No. S7-20-21
From: B. Lewis

February 18, 2022

(Comments on: S7-20-21 Rule 10b5-1 and Insider Trading)

Hello I have a concern regarding this part of the rule amendment:

\"Require officers and directors to personally certify that they are not aware of material nonpublic information about the issuer or the security when they adopt a Rule 10b5-1 trading arrangement\"

As I have reason to believe that someone simply stating that they have no knowledge of information isn't very reliable, maybe disallow directors, managers, etc. (any persons who would have access to this kind of information) from trading a stock their company manages altogether?
I understand that can end up being a lot of tickers-- escpecially when they get into sub-companies and offshoot business under the \"parent\" business-- but honestly staying truly in the dark is the way I think would be the most effective. After all, the rest of us are in the dark all the time anyways.

I guess a personal addition to this would be that I am a former NCAA athlete. We were (and still are) never allowed to bet on games in any form that would potentially result in monetary gain. The rule was in place to keep the integrity of the game and to keep competitions as natural and organic as it can be.
That was okay, though, because understood why. We knew the consequences of us being allowed to bet, so nobody complained. We knew it was for the benefit of everyone participating.

Thank you for allowing me this opportunity, and thank you for your time.

B