From: Doug Mohn
Sent: July 14, 2016
Subject: File Number S7-06-16

I would like to comment on Item 201(b) listed on page 173 of the Business and Financial Disclosure Required by Regulation S-K concept.  

I am individual investor who like to call to attention the current definition of the SEC uses that only counts shareholders of paper certificates to be a “shareholder of record.”  For example, in GM’s latest 10-K, the company states, “At January 27, 2016 we had 1.5 billion issued and outstanding shares of common stock held by 447 holders of record”.   It is ludicrous to believe that GM only has 447 shareholders as that would imply each shareholder of GM owns 3.5 million shares each! Yet, this nonsense exists everywhere in SEC filings because the definition of a shareholder of record was set fifty years ago before the internet was invented.  It needs to be updated to reflect current practices.

While responsible companies will treat people who own shares at their brokerage the same as people who own paper certificates, some shareholder unfriendly companies hide behind the SEC rules and deny those of us holding our shares in street name, the same rights to company information and proxy access by claiming we are not the shareholder of record. These companies are effectively disenfranchising the mass of shareholders who own their shares through Fidelity, Schwab, E*TRADE, Scottrade, TD Ameritrade, Interactive Brokers, and the rest.

I believe it is time that the SEC update its definition of shareholder of record to include shares held at the many discount brokers used by ordinary citizens as “Shareholders of Record”.

Thank you for your consideration,

Doug Mohn
Katy, TX