Subject: S7-18-21: WebForm Comments from William Ferguson
From: William Ferguson
Affiliation: Commercial Real Estate Valuation Consultant

Aug. 16, 2022

August 16, 2022

 For years, the Real Estate Industry which is controlled by the National Association of Realtors (America's Largest Trade Association) has contested the disclosure of detailed real estate transaction and/or sales data to maintain an edge or advantage over their non-member competition.  This has contributed to a number of significant economic corrections such as the \"Savings  Loan\" crisis and the \"Mortgage\" crisis.

Now, the Securities Industry is coming out to contest the proposed disclosure of transaction-by-transaction reporting and resulting increased transparency to overt or significantly reduce future financially corrections.

As an investor, I am in favor of the SEC Rule 10c-1 proposal and opposed to diminishing the recommendations as a favor to the Security Industry participants.