Subject: File No. SR-NYSE-2024-35
From: Andrew Gadlin

As an individual investor, I have frequently invested in Closed End Funds in order to capitalize on the discounts that often materialize in these investment vehicles. If this rule goes into effect, then the entire asset class becomes uninvestable, in my opinion. When I purchase a close end fund, I take comfort in knowing that if the fund is trading at a material discount, then an activist investor will show up at the annual meeting and push for the manager of the fund to reduce the discount through some shareholder-friendly action. If managers do not have a requirement to hold annual meetings, then there is truly no limit to how large a discount may develop. To see examples of this, one can simply look at the CEF's that have a concentrated ownership that prohibits this type of shareholder friendly action -- these funds can trade at discounts of 50% or more! If this rule goes into effect, then every fund is at risk of trading for such a discount and the entire asset class needs to be sold.