Mar. 24, 2023
Just a quick adding of my voice to opposition to exceptions/exemptions to this rule. I am NOT in favour of giving any kind of special status to any person or organization such as a Market Maker, Prime Broker, or other such entity. A rule should apply to ALL. Here are some examples of potential loopholes in the proposed rule: Risk-mitigating hedging activities: This exception would allow securitizers to engage in hedging activities to reduce their risk exposure related to the securitization, but it could be exploited to engage in conflicted practices. For example, a securitizer could engage in hedging activities that benefit their own interests at the expense of investors in the securitization. Bona fide market making: This exception would allow securitizers to make a market in the securities being securitized, which could be used to ensure liquidity and pricing stability in the market. However, it could also be used as a loophole to engage in conflicted practices. For example, a securitizer could artificially manipulate the market to benefit their own interests. Certain liquidity commitments: This exception would allow securitizers to make certain commitments to provide liquidity in the event of market disruptions or other contingencies. While this is intended to ensure the stability of the securitization market, it could also be used as a loophole to engage in conflicted practices. For example, a securitizer could use this exception to avoid losses at the expense of investors in the securitization. Once again I do not support any of the proposed exceptions on this rule. Thank you for listening.