Subject: File No. S7-03-20
From: R T Leuchtkafer

May 20, 2020

The proposal is a very substantial effort and the SEC is to be commended for it. Unfortunately the events of the last three months have made it very difficult to give this the attention and thought it deserves. I hope the SEC will substantially extend the comment period or even suspend proceedings through the summer to give us all more time to digest and comment.