Mar. 23, 2023
March 23, 2023
Mar. 23, 2023
Hello,
I write to you today as an international investor with concerns about proposed rule to implement Section 27B of the Securities Act of 1933, a provision added by Section 621 of the Dodd-Frank Act. I remain unconvinced that granting exceptions to any parties is a good idea. It's not wise to allow wiggle room to bad actors who routinely flout the SEC's rules. In addition, offering exemptions to market makers undermines the basics of a fair market, and certainly puts individual investors at a disadvantage.
I would ask that the SEC probe the reasons these exemptions are being requested. Why is the SEC responsible for mitigating the risks that private corporations willing take on? Why are liquidity commitments in question? Shouldn't market makers always have the requisite liquidity on hand as advised by the SEC? As I see it, if a market maker chooses to run their business in an irresponsible manner and ignores the SEC's liquidity rules, that is their choice. They are opting for a riskier business model and by their own reports, they have been very successful. Should the need for liquidity arise and they are forced to sell assets quickly at a loss, is that not just part of their business strategy? Did they not save profits from fat years to cover the lean years? Do they refuse to move profits to cover their obligations? The truth is that poor business decisions often mean failed businesses. Ethically, I do not consider it in the SEC's purview to intervene when these knowledgeable and capa
ble entities choose high risk strategies.
These businesses requesting exemptions already act as the gods of the stock exchange racking up violations and fines as a part of business, conflicts of interests everywhere you look. I can't imagine a more lax rule would encourage better behaviour. Personally, I am staunchly in favour of a truly fair market for all and so I urge you to reconsider all exemptions to this rule.
Thank you for the opportunity to comment on this proposed rule. I appreciate you time and thoughtful consideration.
Sincerely,
J. Campbell