Subject: S7-01-23: WebForm Comments from Jeffrey Vongermeten
From: Jeffrey Vongermeten
Affiliation: Medical technologist

Mar. 15, 2023



March 15, 2023

 There should be zero exceptions to conflicts of interest.

Do NOT, by any means, create loopholes circumventing the entire purpose and spirit of this rule.

Providing conflict of interest exceptions for risk-mitigating hedging activities, bona fide market making,  certain liquidity commitments does NOT improved the functioning of the markets, it merely contaminates them.

Rather than create exceptions for those who would mitigate the risk of their actions by engaging in a conflict of interest, why do we not simply suggest that if they feel such a strong need to mitigate such risk, that perhaps they should AVOID STRATEGIES THAT EXPOSE THEM TO RISKS THEY ATE UNCOMFORTABLE TAKING. And if they choose to take such risks, they do so at their own peril, and should not expect systemic accommodation of their corruption to save them from bad strategies or to create loopholes that allow them to engage in ANY conflicts of interest.