June 27, 2023
Dear Sir/Madam,
Please consider my comments regarding the proposal 's7-06-22 Modernization of Beneficial Ownership Reporting'.
I wholeheartedly support the accelerated disclosure timeline for reporting. The existing disclosure timelines are archaic and have not kept up with modern day communications,leaving far too much room for underhanded and secretive accumulation practices.Its time that reporting kept up with the times to serve the widest possible capital market participants, rather than a select few that have been able to use the lax reporting standards to their advantage and the detriment of others.
The inclusion of derivatives into the definition of beneficial ownership will negatively affect the capital market structure without further clarification surrounding the voting rights that beneficial ownership grants. Voting in corporate governance events is the backbone of participating in capital markets yet the voting system is complex and opaque with over-voting seemingly common. If not addressed, I believe that participants will exploit these loopholes as has been shown time and time again.
Please consider these comments and thank you for the opportunity to participate in rulemaking for capital markets.
-A