Subject: File No. S7-32-10
From: Robert Jarvis

February 7, 2022

While I'm happy that rules such as these are being put forward and look forward to seeing more in future, my recent experience of investing in the US market has left me cynical that they will make a difference.

Fines for breaking rules seems to be accepted as a 'cost of doing business' by Wall Street. It seems like punishments are not reflective of the damage they cause, both monetarily, and to the reputation of the market as a whole (and the bodies charged with oversight such as the SEC).


In short, offending parties that violate these rules need to be:

1) Identified more quickly, with more tools being made available to make the required information transparent and unearth entities that misreport or mislead with their finances.

2) Punished appropriately with material fines or legal consequences to the extent they outweigh any benefit gained through rule breaking and that impact both firms and individual executives.