Mar. 23, 2023
March 23, 2023 I suggest that the proposed rule be revised to exclude exceptions for risk-mitigating hedging activities, bona fide market making, and certain liquidity commitments. These exceptions would undermine the effectiveness of the rule and create loopholes for securitizers to engage in conflicted practices. I also urge the SEC to expand the scope of their target to cover collateralized debt obligations (CDOs). CDOs have been a source of numerous conflicts of interest and abuses, and their inclusion in the rule would promote transparency, protect investors, and maintain the integrity of the financial markets.