Mar. 3, 2023
March 3, 2023 I am writing in strong support of the proposed Rule 192, pursuant to Section 27B(b) of the Securities Act. As a concerned investor, I believe that the implementation of this rule is essential to protect investors against material conflicts of interest that can arise in securitization transactions. The proposed rule is designed to prevent securitization participants from engaging in transactions that could incentivize them to structure ABS in a way that puts their interests ahead of those of ABS investors. By focusing on transactions that represent a \"bet\" against the performance of an ABS, the rule provides an explicit standard for determining which types of transactions are prohibited. This is an important safeguard against the misconduct that led up to the 2007-2009 financial crisis, and the re-proposed rule takes into account developments in the ABS market since 2011 to provide greater clarity regarding the scope of prohibited and permitted conduct. As a retail investor who relies on the integrity of the financial system, I believe that it is crucial to have confidence in the securitization market. The implementation of this rule would complement existing federal securities laws that specifically apply to securitization, as well as the general anti-fraud and anti-manipulation provisions of the federal securities laws. In conclusion, I urge the SEC to move forward with the proposed Rule 192 to protect ABS investors against material conflicts of interest. Thank you for your consideration of this important matter.