April 11, 2022
Given the fact that incompetence, anti-Black discrimination and exclusionary practices based on race are currently operational in investment and finance, including at the SEC and other regulatory bodies, we decline to directly address the questions raised, having done so over the past 30 years. Additional specific input would be futile. We include the following by reference:
On July 3, 1993, WMC wrote to SEC Commissioner Mary Schapiro to notify the Commission about a certain, specific investing \"scam.\" A timely warning was not issued to the investing public and members of the public were damaged. See: https://www.creativeinvest.com/SECNigerianLetter.pdf
WMC designed the first mortgage security backed by home mortgage loans to low- and moderate-income persons and originated by minority owned institutions. (See: Security Backed Exclusively by Minority Loans, at https://www.creativeinvest.com/mbsarticle.html )
On February 6, 2006, statistical models created by WMC using the Fully Adjusted Return Methodology signaled the probability of system wide economic and market failure. (See page 2: http://www.sec.gov/rules/proposed/s71005/wcunningham5867.pdf )
Mr. Cunningham has a long track record of analyzing proposed regulatory agency rules:
Our 2003 comments on proposed proxy voting rules that would, under certain circumstances, require companies to include in their proxy materials security holder nominees for election as director. https://www.sec.gov/rules/proposed/s71903/wmccir122203.pdf
See: Comments on Proposed Rule: Internet Availability of Proxy Materials Release Nos. 34-52926 IC-27182 File No. S7-10-05. Confirmed that system-wide economic and market failure was a growing possibility. (See page 2: http://www.sec.gov/rules/proposed/s71005/wcunningham5867.pdf )
Shareholder Proposals Relating to the Election of Directors. Release No. 34-56161 File No. S7-17-07 https://www.sec.gov/comments/s7-16-07/s71607-495.pdf
We have requested that the U.S. Securities and Exchange Commission (SEC) develop mandatory rules for public companies to disclose high-quality, comparable, decision-useful information concerning BLM Pledge fulfillment. See: https://www.sec.gov/rules/petitions/2021/petn4-774.pdf