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<p><span>Thank you, Chair Gensler, and thank you to the staff for their presentations. Today, the Commission considers three separate, but related proposals. In discussions with the staff, the three proposals have been described as having different objectives and not being limited solely to cybersecurity. Despite that view, each proposal places a significant focus on cybersecurity. In fact, that term is mentioned over 250 times in the Regulation S-P and Regulation SCI proposals, and over 2,000 times in the cybersecurity risk management proposal. However, the Commission has provided little analysis as to how the proposals interact with each other or how, as a group, they mitigate cybersecurity risks in the most efficient manner. The lack of an integrated regulatory structure may even weaken cybersecurity protection by diverting attention to satisfy multiple overlapping regulatory regimes rather than focusing on the real threat of cyber intrusions and other malfeasance. Thus,

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