March 28, 2022
I am writing in favor of the proposed rule change. The subscription warrant structure would promote just and equitable principles of trade in our capital markets, which are currently tilted to favor wealthy individuals, institutions, and investment banks.
Subscription warrants would offer improved access for ordinary investors to participate in new opportunities through a more efficient and cost-effective structure that reduces conflicts of interest and opportunity cost while enhancing competition, transparency, and alignment of interests.
On the topic of valuing subscription warrants, Mr. Hui Chen of the MIT Sloan School of Management did an excellent job explaining in technical terms what most investors already understand in layman's terms. His comments were submitted to the SEC on January 4, 2022.
The NYSEs amended proposed rule change provides safeguards which adequately address concerns that subscription warrants may be susceptible to manipulation. Even large companies with very high stock prices have been, and continue to be, the subject of manipulation. Regardless, I believe investors should be able to decide which risks to take.