Jul. 29, 2023
Dear SEC Public Comment Review Committee, Based on my review of the proposed SEC rule (S7-06-22), here are some potential positives for retail investors: Shortening the filing deadlines could allow retail investors to access information about large share acquisitions and changes in ownership more quickly. This could help them make more informed investment decisions. Requiring reporting on certain derivative securities could give retail investors greater visibility into how large investors leverage complex instruments that reference the underlying stocks. This could help reveal some influential positions that are currently opaque. Clarifying the definition of 'group' could prevent sophisticated investors from skirting reporting requirements when coordinating accumulations of significant stakes. This helps ensure retail investors have fair insight. Allowing more communication between large investors could facilitate shareholder engagement and the promotion of long-term value. This could indirectly benefit retail investors. Machine-readable structured data could allow better analysis and tracking of beneficial ownership by retail investors using public filings. The additional economic analysis being sought could shed light on whether the intended transparency benefits justify any incremental burdens on filers. So in summary, the main benefits are enhanced transparency, timeliness of reporting, and improved data quality/accessibility for retail investors. But the actual impacts will depend on the final rule details and weighing of various tradeoffs based on data and feedback. I believe the proposed changes in rule S7-06-22 seem positively oriented toward protecting retail investors by improving transparency around significant share ownership and control. Shortening reporting deadlines, expanding derivative reporting, and requiring machine-readable filings should improve the timeliness and accessibility of beneficial ownership data for everyday investors. Thank you for the SEC's continued fight against collusion, corruption, and opacity in the financial markets. Long may it continue. Phillip