Mar. 23, 2023
Dear Sir or Madame, I am writing to express my concern with regards to rule S7-01-23 and the proposed exceptions to the risk retention requirements for securitizers. While I appreciate the SEC's efforts to provide flexibility to securitizers and promote liquidity in the securitization market, I believe that the proposed exceptions could be exploited to engage in conflicted practices and harm household investors. The bona fide market making exception, while intended to promote liquidity and pricing stability, could also be used as a loophole for securitizers to artificially manipulate the market and benefit themselves. The risk-mitigating hedging activities exception could be exploited by securitizers to engage in conflicted practices that benefit themselves at the expense of investors. The certain liquidity commitments exception, while intended to ensure the stability of the securitization market, could be abused by securitizers to avoid losses at the expense of investors. Given these concerns, I regret to inform you that I cannot support the proposed rule S7-01-23 and the exceptions to the risk retention requirements for securitizers. I urge the SEC to reconsider these exceptions and work towards a rule that provides sufficient protections for investors while also promoting liquidity in the securitization market. Thank you for your attention to this matter. Sincerely, Lars Wohlfahrt