Subject: File No. CLL-16
From: Kathryn Jacobs

As a long-term individual investor who relies on broadly diversified index funds for retirement security, I am writing to express my opposition to rule changes that would facilitate the "fast-track" inclusion of newly listed companies. My primary concerns are: Loss of Quality Filters: Current seasoning requirements act as a vital guardrail. Allowing companies to access index inclusion without a proven record of profitability exposes passive investors to unnecessary, hype-driven volatility. The Impact of Forced Buying: Because I hold index-based products, these funds are effectively "forced" to purchase shares of new companies immediately upon index inclusion. If these firms are unproven or lack sustainable earnings, my retirement portfolio is forced to bear the risk of potential devaluation without the price discovery provided by a sufficient seasoning period. Prioritizing Market Integrity: The stability of major indices is a bedrock of the U.S. retirement system. I urge the Commission to prioritize the financial transparency and long-term viability of companies over the speed of market entry. I request that the Commission maintain or strengthen standards for profitability and financial disclosure before granting companies the benefits of streamlined registration or index eligibility. The integrity and quality of public companies must remain the Commission’s top priority.