Mar. 23, 2023
March 23, 2023 Dear SEC, I must express my strong disagreement with the proposed exemptions in the rules for Section 27B of the Dodd-Frank Wall Street Reform and Consumer Protection Act. While I understand the need to address risk-mitigating hedging activities, bona fide market-making activities, and liquidity commitments, these exemptions, as outlined, may inadvertently create loopholes that undermine the core purpose of the regulation, which is to protect investors and prevent material conflicts of interest. The exemptions for risk-mitigating hedging activities and bona fide market-making activities, in particular, could be exploited by unscrupulous market participants to engage in practices that are against the spirit of the regulation. This would create an unfair playing field and potentially harm investors. Moreover, the reliance on compliance programs and written policies and procedures may not be sufficient to prevent abuse of the exceptions. The financial crisis of 2008 clearly demonstrated the limitations of self-regulation, and I believe that a more robust regulatory framework is needed to ensure the integrity of the financial markets. I urge the SEC to reconsider these exemptions and tighten the rules to prevent potential abuse. This would better serve the interests of investors and maintain the stability and transparency of the financial markets. Kind Regards Daniel