In regards to the Modernization of Beneficial Ownership - Only shareholders should receive beneficial rights. I do not support the proposal that allows certain cash settled derivatives holders against the underlying asset beneficial voting rights. I do not agree that filers of 13D & 13Gs, who hold certain cash-settled derivatives, should be deemed beneficial owners of the reference equity securities. The potential exemptions to permit such persons to receive beneficial shareholder ownership is criminal and illegal; and, should not be seen as equivalent to true equity shareholders. In an effort to appease Wall Street, there was a 5 day subtraction for the current reporting deadline - the cost of better reporting for shareholder rights. I am opposed to this as well as it does not go far enough in demanding immediate reporting for all positions held by anyone in the market. In short, I do not support this proposal and reject it's attempt to codify insider trading, etc.