Subject: S7-04-23: Webform Comments from Hassan Nasori Tehrani
From: Hassan Nasori Tehrani
Affiliation: Capital markets are being shaped by innovation and new technologies. Many of these developments will enable greater access to capital markets. They also bring new financial products, business models, and competitors into the markets. At the same time, how

Aug. 29, 2023

Capital markets are being shaped by innovation and new
technologies. Many of these developments will enable greater access to
capital markets. They also bring new financial products, business
models, and competitors into the markets. At the same time, however,
this dynamic places additional demands on SEC resources—not only in
examinations and enforcement matters, but also in new rulemakings and
policy areas.

Transaction costs have come down, and efficiency and fairness have
increased in many markets. However, increased use of, and reliance on,
technology has introduced new risks and, in some cases, amplified
better-known market risks. For example, cybersecurity threats to the
complex system that helps the markets function are constant and
growing in scale and sophistication.

Similarly, markets are more interconnected and interdependent than
ever. They function on a 24-hour cycle and cut across geographic
barriers. Information from one market travels to others in fractions
of a second. Trillions of dollars of capital flow across markets each
day—amounts that would have been unimaginable only a few decades
ago. These developments create regulatory and oversight challenges as
the operations of large investment firms extend well beyond U.S.
borders, and new entrants to U.S. markets seek to avoid or evade U.S.
securities laws. The need for coordination with fellow financial
regulators, including foreign regulators, will continue to rise.

2.1 Update existing SEC rules and approaches to reflect evolving
technologies, business models, and capital markets.

The ongoing movement of assets into private or unregulated markets,
the continual creation of new financial instruments and technologies,
and the challenges of increased globalization all require the agency
to rapidly update and evolve.

To do so, the SEC must enhance transparency in private markets and
modify rules to ensure that core regulatory principles apply in all
appropriate contexts. To maintain the integrity of the markets, the
SEC needs to develop specific regulations to ensure investors remain
informed and protected via a broad-based disclosure frameworks.

The agency must also continue to focus on supervising global entities
appropriately. Inherent in the interplay with international markets is
the challenge of protecting sensitive information when coordinating
with other regulators. Consistent data protection policies are
essential for this effort.
2.2 Examine strategies to address systemic and infrastructure risks
faced by our capital markets and our market participants.

Future market volatility driven by market or external events such as
the pandemic, the evolution of markets without subsequent
strengthening of agency authorities, and the rapid growth in crypto
assets all represent evolutionary risks.

To be better prepared for, and more agile in, its response to such
risks in the future, the SEC must pursue new authorities from Congress
where needed, continue to effectively collaborate with other
regulators, and engage more proactively on digitization initiatives.
2.3 Recognize significant developments and trends in our evolving
capital markets and adjust our activities accordingly.

To help ensure a systematic, timely, and collaborative response to
market developments, the SEC must continue to apply its three-part
mission holistically, not in isolation. Investor education and
outreach must continue to focus on diverse and underserved communities
as well as on emerging and popular investment topics. These efforts
should reflect input from stakeholders, including retail investors,
via proactive outreach, roundtables, and field hearings.

The SEC must also continue to enhance its expertise in, and devote
increased resources to, product markets beyond equities—including
crypto assets, derivatives, and fixed income—and maintain a nimble
and flexible approach to address market changes expeditiously.