March 21, 2022
I am writing in strong support of SR-NYSE-2021-45 as amended by Amendment No 2. I believe the amendment satisfies SEC concerns raised in Release No. 34-93741.
As a previous SPAC investor, thorough research has led me to conclude that the subscription warrant structure described in SR-NYSE-2021-45 (otherwise referred to as SPARC structure) is far superior. That said, I'm not against the current SPAC structure as-is, even though I concede there are some limitations. SR-NYSE-2021-45 fixes all of these limitations and more.
The SEC has stated interest in improving blank check investment vehicles numerous times. Here is an opportunity to do just that. These subscription warrants are a vast improvement in structure and offer investors (especially retail investors) the ability to make a more informed decision before committing capital.
Others here have laid out all the benefits far more eloquently and detailed than I could hope to. I agree with much of what has been said after reading through all arguments for and against. The only reason I can think of for anyone to be against this amendment is due to an ulterior motive.
I would like to end by saying that if the SEC is truly devoted to protecting investors, then I see absolutely no reason to not let this amendment pass.
Thank you for your consideration.