Subject: S7-13-22: WebForm Comments from ACP Capital Markets
From: Sagiv Shiv, Managing Director, Head of MA and Advisory, ACP Capital Markets LLC
Affiliation:

Mar. 24, 2023

March 24, 2023

 the part of the SPAC phenomenon i find most egregious and adverse to true investors (as opposed to hedge fund flippers) is that the underwriters receive full fees on the IPO gross amount, while in reality close to 100% of the trust is redeemed.
thus, the combined company starts life with negative cash while the underwrites receive handsome rewards for providing negative value.
Underwriting fees should be placed in the trust and paid only for those amounts released to the company upon the combination.
Respectfully,
Sagiv Shiv
Managing Director, Head of MA and Advisory
ACP Capital Markets LLC