Mar. 24, 2023
March 24, 2023
Sir/Ma'am,
I am writing to express my strong opposition to the proposed Rule 192 exceptions release no.33-11151, which seeks to amend the current exceptions to the Rule 192 under the Securities Act of 1933. As a retail investor, I believe that the proposed changes would have significant adverse retail investors and favorable to participants related to hedging activities.
Participants related to hedging activities are sophisticated people, who have more capital, and expertise on choosing which investments to get involve with. With such resources and talent, I would believe that they are intelligent to have consider possible outcome of their investment without proper Risk Management. Under the proposed rule 192, exception for Risk-Mitigating hedging activities allowing securitization participants sufficient flexibility while they have overhedged their position is strongly favorable to the participants of hedging activities and could lead to deceitfulness and strongly harm not just the issuers but also investors.
Removing liquidity commitment is absurd. Contractual obligations to provide liquidity is ensuring clarity and certainty, providing security, encouraging good faith and fair dealing, protecting interests, and promoting accountability. This is essential for any business transactions as it helps establish a foundation of trust and reliability between parties involved.
I strongly urge the SEC to reconsider the proposed Rule 192 exceptions release no.33-11151. The SEC should instead focus on promoting greater transparency and investor protection measures.
Thank you for your consideration.