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Sept05re DOC FORM 4 Statement of Changes in Beneficial Ownership Filed 012412 for the Period Ending 012012

Sept05re DOC FORM 4 Statement of Changes in Beneficial Ownership Filed 012412 for the Period Ending 012012

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hi i'm gail bernstein general counsel of the investment advisor association on april 11th we submitted comments regarding the sec's proposal to modernize beneficial ownership reporting while the iaa agrees that these rules could benefit from modernization we have several concerns with the proposed updates i will mention three first the proposal would drastically shorten timelines for filing we believe that this will not provide enough time for accurate and complete reporting and we recommend changing the proposed schedule to provide more time create consistency and reduce confusion second the sec would extend reporting to certain cash settled derivative securities even though the holders have no voting power and no ability to influence control of the issuer we think this is unnecessary overly complicated and inconsistent with the purpose of beneficial ownership reporting third the proposal would also expand when two or more people are considered a group and thus require

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