Mar. 24, 2023
March 24, 2023 (A) I disagree with the proposal that prohibit employee ownership of sector funds that have a stated policy of concentrating their investments in entities directly regulated by the Commission. Reasons: 1. Investing in sector fund provides an opportunity for employees to diversify the risk and restricting them will increase such risks substantially. 2. This restriction will prohibit employees' participation in the progress made by the industry in which employee has built his/her own career. That would be a shame 3. Lot of spouses of SEC employees work in Financial Industry and are already not able to participate in company benefits such as stock options due to prohibition and this proposed restriction on sector fund will create more hardship as family members (spouses and children) will be discouraged to pursue career in Financial Industry. 4. History does not appear to indicate that any employee individually or collectively, can create conflict so substantial that can impact the mission of the agency in leu of personal gains. (C) I disagree with the proposal to require SEC employees to use an automated reporting system for compliance with employee ethics rules. Reasons: 1. Signing up and maintaining an automated reporting system will create huge burden on the employee and the industry. Burden can include more direct or indirect cost to the employee to maintain and provide the data to the SEC. Industry would incur cost due to many reason including creating new infrastructure, employees and cyber attack preventions. 2. Privacy concerns: For example, would the automated system redact irrelevant private information, such as the address and account number of the SEC employee, spouse, or dependent child? 3. Would the burden be on the SEC employee to stop the automated reporting when the dependent child becomes an adult, or when the SEC employee leaves the SEC? 4. Who and how will the issue be resolved if the data is corrupt? 5. What happens if the broker does not wishes to transfer data directly to SEC? Employee should not be forced to close the accounts. Not all brokers may have ability to provide data to 3rd party on periodic basis.