Dec. 15, 2021
To Whom It May Concern: Thank you for taking a look at the insider trading plan disclosures which I feel is a much needed review. As part of this effort I encourage the SEC to also consider improvements to Forms 4 and 5 to make these disclosures more informative and clear. When reviewing a Form 4 filing I am interested in determining the magnitude of the transaction for the filer which requires a review of proxy filings to determine the executive’s aggregate economic exposure across all securities before the transaction was made. I also endeavor to calculate an executive’s cost basis (to the extent the exec bought shares with personal funds) which involves the review of their Form 4s across their career. I propose a simple plain-English summary of the filer’s total ownership of the company’s equity, units, options, debt, etc after the transactions took place with specific disclosure on the % change of ownership of each of the relevant securities. This will allow all investors to quickly and clearly see the significance of any given transaction. For purchases, I think it’s critical that it’s abundantly clear in the Form if the buy was funded with the executive’s capital or came from the company. The SEC has a page long list on Form 4’s Transaction Codes which are confusing for a professional investor and likely meaningless for the average retail investor. Sincerely, -John Frank John Frank