Subject: S7-32-10: WebForm Comments from Michael Kammer
From: Michael Kammer
Affiliation: Professor of Medicine, Vanderbilt University Medical Center

Oct. 30, 2022



October 30, 2022

 If adopted, these new rules would:

1) Reduce the number of days investors have to disclose a 5 percent stake in a public company from 10 days to 5 days

2) Require disclosure of derivative positions to ensure that they are not used exploitively or hide something significant.

3) If two or more investors have formed a group and own more than 5 percent stake, then the circumstances would be disclosed.


By inhibiting the ability of market participants (mainly activist hedge funds with short-term investing strategies) to take advantage of outdated reporting requirements, these rules will also help workers and retirement saverswhile keeping the ability of shareholders to communicate with corporate management about environmental, social, and governance (ESG) topics if they desire. Therefore, Iendorse the proposed rules and urge you conclude them rapidly.


These proposed rules will reduce the potential for future market crises and increase transparency, benefiting workers and retirees. I urge you to finalize these new rules as soon as possible.