Mar. 15, 2023
Sir/Ma'am, I am writing in regards to rule 192, prohibiting a securitization participant from engaging, directly or indirectly, in any transaction that would involve or result in any material conflict of interest between the securitization participant and an investor in an ABS, subject to certain exceptions. I believe our current markets are not fair and transparent, and as an individual investor the deck is heavily stacked against me. I appreciate the SEC's efforts lately in trying to propose ways to level the playing field and extend my gratitude. However, I have concerns regarding the "exceptionsto rule 192, specifically section 27B. I think the exception of "Risk-mitigating hedging activities, Bona fide market-making activities and Liquidity commitmentsleaves some room for exploitation. I firmly believe market makers still have the feasibility and the intent to take advantage of their position and there is still substantial room for a conflict of interest and the same for the hedging strategy exemption. If you are going to implement this rule, which you certainly should, there should not be any exceptions. Please allow myself and other individual investors to have some skin in the fight. Very respectfully, Gregory B. Marti