March 11, 2022
I am in favor of the SR-NYSE-2021-45 proposed rule change.
As an investor in a number of SPACs, I have found the investment vehicle lacking, especially as a retail investor when capital is \"locked-up\" for extended periods of time and sitting idle.
With regards to SPARCS, the proposed subscription warrants go a long way to improve some of the shortcomings of SPACs, while not creating any adverse conditions for investors.
I know that a primary concern regarding subscription warrants is that they may be manipulated by rumors or deals without definitive agreements - something that impacts SPACs today, since existing common shares, warrants, rights, and options related to a specific SPAC could be subject to market manipulation. Since these subscription warrants will not be optionable they will be less subject to manipulation than other equities, provided the float size is sufficient.
The SEC has stated its interest in improving SPACs. These subscription warrants can be a step in the right direction.