Mar. 23, 2023
This rule could greatly benefit retail investors if said rule has the exemptions removed. Issuing rules with loopholes to circumvent the rule written in gives the appearance of enforcement while giving those abuse these rules the means to undermine capital markets. From the SEC site- “The proposed rule would provide certain exceptions for risk-mitigating hedging activities, bona fide market-making activities, and certain commitments by a securitization participant to provide liquidity for the relevant ABS. The proposed exceptions would focus on distinguishing the characteristics of such activities from speculative trading. The proposed exceptions would also seek to avoid disrupting current liquidity commitment, market-making, and balance sheet management activities.” I would argue that all these exceptions need to be removed. Liquidity is not the main priority here, all too often true price discovery and maintaining fair markets where securities are delivered in a timely fashion is thrown out the window for the sake of liquidity. Stop writing rules with exemptions that cut the rule off at the knees and take away any hope of the rule making a positive impact. Thank you for your consideration in this matter, A concerned retail investor