Subject: File No. S7-21-21
From: J Mintzmyer

December 21, 2021

I am a significant supporter/proponent of this proposal, both as an investor and trader and also as an independent research analyst.

This measure would significantly improve transparency in the market and reward the companies who are legitimately repurchasing their shares on a consistent basis versus those who are arguably manipulating the market via either a) announcing a repurchase and never using it consistently b) applying their repurchase program in an inconsistent and market manipulating manner.

If this measure passes, it would still allow companies to return value to shareholders via repurchases, but it would both eliminate the 'bad actors' as well as encourage firms to consistently utilize their programs.

You have my full support for this measure. However, I would argue the far bigger abuse and manipulation comes from the other side, which is At The Market (ATM) offerings or Continuous Offering Programs (COP), which allow firms to sell shares into the market on a daily basis.

This is basically just the exact reverse of a repurchase. Please consider the exact same regulation for these measures, if anything ATM/COP filings should be more imperative than repurchase filings.