Mar. 24, 2023
To whom it may concern, Please accept this email as a strong recommendation - even a fervent plea - to disallow the loopholes present in File No. S7-01-23. Such potential loopholes include, but are not limited to: Certain Liquidity Commitments: The exception would allow securitizers to make commitments to provide liquidity during market disruptions or other contingencies. This is intended to ensure the stability of the securitization market, but instead it would be used as a loophole to engage in conflicted practices. A securitizer could use this exception to avoid losses at the expense of investors in the securitization. Bonafide market making: The exception would allow securitizers to make a market in the securities being securitized, which would be used to ensure liquidity and pricing stability in the market. However, it would also be used as a loophole to engage in conflicted practices such as when a securitizer artificially manipulates the market to benefit their own interests. Risk mitigating hedging activities: The exception would allow securitizers to to engage in hedging activities to reduce their risk exposure but would be exploited to engage in conflicted practices. A securitizer could engage in hedging activities that benefit their own interests at the expense of investors in the securitization. In sum, File No. S7-01-23 serves only to help large Market Makers such as Virtu and Citadel by providing a bevy of loopholes to take advantage of. The poorly written measures would be detrimental to the markets and retail investors and should be struck down. Semangat, Chris Hulshof Anak Semua Bangsa GETSEA Director of Community Engagement Department of History University of Wisconsin-Madison 3211 Mosse Humanities Building 455 N. Park St., Madison, WI 53706 Mailbox: 4116 - WhatsApp: 661-972-7123 -- Office Hours Sign-Ups