Mar. 15, 2023
Greetings, I applaud the commission for revisiting the rules proposed after the Great Financial Crisis that would prohibit transactions that would result in material conflicts of interest. However, I wanted to comment the following: I do NOT support the exceptions. "Market making and certain liquidity commitmentsin particular should not be exempt from these conflict of interest prohibitions. If ABS packages are in short supply, but still in demand, then the price for those securities should reflect that reality the same way they would for a tangible good. Furthermore, if the security is questionable, and a party wishes to hedge against that security, they should be required to disclose their positions to any clients from whom they are taking money for investments contrary to the firm. No party or entity should be exempt from prohibition of conflicts of interest. There should be no loopholes for prohibiting conflicts of interest! I wish I didn't have to explan why I object to these exemptions, but I must: household investors are not privvy to the same information as insitituional investors. It is not that they are less sophisticated, it is that the information is deliberately witheld to create an advantage for institutions. By allowing exemptions for any entity, not only are those household investors who are unsophisticated likely to lose their investment, but even the most experienced, dedicated household investor can make investments based on fragmented information and risk losing money. If conflicts of interest are prohibited for ever single entity in the market, the risk of an investment is lowered and any loss an investor faces will not be due to an entity deliberately misleading them in the name of "liquidity. In short: the proposal as written is unacceptable. There should be no exemptions for any rules intended to make our markets more fair. Thank you for taking the time to review my comments on this proposal.