Subject: Re: Prohibition Against Conflicts of Interest in Certain
From: Terry ho
Affiliation:

Mar. 15, 2023


Securitizations File No. S7-01-23
Content:
Make clear that you don’t want any so called exceptions for “risk-mitigating hedging activities, bona fide market making & certain liquidity commitments”.
 
The proposed rule exempts non-reporting companies from registering certain securities offerings under the Securities Act, if they are exclusively sold to accredited investors. However, this exemption has significant flaws The proposed rule inadequately protects household investors by reducing the information available to them. This lack of transparency makes it harder for them to make informed investment decisions, potentially leading to losses. The proposed rule could be exploited by manipulative hedge funds. These funds have a history of manipulative behavior in the securities market, and the exemption would offer them a new opportunity to engage in such practices. By limiting the exemption to accredited investors, hedge funds could create fake accredited investor accounts to conduct manipulative behavior outside of regulatory oversight.  
Market makers should not be exempt.  No one should be exempt.