Apr. 25, 2023
Secretary Securities and Exchange Commission 100 F Street, N.E. Washington, D.C. 20549-1090 Re: Comment Letter for File Number S7-08-23 - Amendments to FOCUS Report Dear Sir, Greetings to the Commission, and thank you for accepting my comment regarding the FOCUS report. A strong and open market operates best when market participants are held to equal standard and data is accessible for review. This proposal details an amendment in which the Securities Act will require the electronic filing of various documents on EDGAR, which is an extremely powerful and publicly available searching resource for financial filings and submissions to the SEC. The main filing, 19b-4e, is required to submit to the SEC after derivative positions are entered by Self Regulatory Organizations. The filing requirements are archaic and not tenable for a modern online era, which include both a manual signature requirement and 9 copies to be submitted alongside the original. (1) Electronic and standardized transmission will improve this process for both the SROs submitting the filing and for the Commission receiving the filings. While the Commission does receive these filings, they are not conveniently available to the savvy investor or the retail public. Although self regulatory organizations likely file 19b-4e by the thousands in context of the gargantuan derivative market, as of 4/17/23 EDGAR only has two available filings of this type in it’s 22-year databank. (2) Consistency and harmony among data submissions while moving closer to a modernization and embrace of digital technology and record keeping are worthwhile goals to frame future policy and amendments around. In addition to creating an easier submission pipeline for all parties, requiring electronic submission will allow for more direct publication of these documents and give more access to an investing public which has become more interested in these details. It is for these reasons I would like to express my support for File No. S7-08-23. 1. https://www.sec.gov/files/form19b-4e.pdf 2. https://www.sec.gov/edgar/search/#/dateRange=all&category=custom&forms=19B-4E Your hard work and commitment to excellence do not go unnoticed. Nic Umbs