Subject: File No. S7-21-21
From: Brit Stephens

January 28, 2022

First, I'd like to express that this proposed rule change should require more meaningful outreach/education of the affected organizations. 45 days is an inadequate window of time for the dissemination of and response to the proposed change.

As some have stated, the change, as currently presented, will NOT realize its intended effect of improving information symmetry and benefitting the entire investor community.

A daily filing requirement will impose significant compliance costs (particularly for smaller organizations) and create mostly white noise via the stream of filing activity that will NOT provide helpful, relative perspective to individual investors (or at a minimum those investors who do not possess the resources to process the data efficiently).

If the intent of the proposed change is to punish/discourage share repurchase activity and/or provide an opportunity to analyze/mine more granular data/trading activity (to the benefit of larger, data-driven asset managers and hedge funds), then this rule change should be extremely effective. I do not believe it will in any way make benefit the individual investor - in fact it will likely make the playing field even more challenging for them.

I also agree with a previous commenter that the requirement to disclose daily purchase information to the marketplace is a burden that no other investor, small individual or large institution, is required to make, which raises a significant fairness issue.

While I do not believe that a change to the current quarterly reporting requirement is necessary, if a change is implemented, a MONTHLY filing requirement makes more sense to all parties involved.