Subject: cll-13: WebForm Comments from John F Phinney
From: John F Phinney
Affiliation: CEO of Convergence Inc

Oct. 09, 2022



October 9, 2022

 Comment 1 - Protecting Investors - The Commission should use the term \"investors\" consistently throughout its plan.  In some pages the Commission refers to \"protecting working families (page 6 and 7)\", \"protecting investors\" (page 7) and individual investors (page 8).\" Comment 2 - The Commission should make efforts to forge public/private partnerships with experts in the field of form creation and forensic and data science to improve DERA's ability to collect more relevant information and spot anomalies in public filings. Comment 3 - The Commission should consider the key control roles played by Fund Administrators and require a form of registration and oversight similar the rules requiring registration and reporting in Ireland.