Aug. 27, 2021
I’m sure you’ve see the attached article in The Economist, a respected ‘newspaper’ published from London. The arguments offered therein are most compelling, and more to the point, logical. I hope it resonates in some way with your own thinking on how PSTH should be handled by the SEC! I have already commented earlier today. This is just something I’m sending to further make my case, even if you must have certainly seen it for yourselves, and more relevantly, already received the link from many other commentators to the proposed rule change! https://www.economist.com/finance-and-economics/out-of-bill-ackmans-spac-woes-comes-innovation/21803915 Out of Bill Ackman’s SPAC woes comes innovation from TheEconomist AJ Jaganathan Owner Director Good Montbeck Holdings, Inc. On 27-Aug-2021, at 8:41 AM, AJ Jaganathan wrote: Dear Chair Gensler / SEC members: I write in regard to #SR-NYSE-2021-45. As a substantial (relative to my net worth!) retail Canadian investor (through a family owned incorporation) on US exchanges, I am compelled to write in and offer my personal views to you, in the hope that it will have some bearing on how you might process the above referred application. I strongly believe that a subscription warrant will provide small investors such as us, access to investing in companies that we otherwise would not have - without needing to tie up excessive capital; real or leveraged. Nor are we able to find financial muscle needed to cosy up to Wall Street bankers that largely only serve to line their own pockets (& their shareholders), and in a smaller way, that of their biggest wealth management clients! We are completely cut out of that very lucrative loop! I’ve no doubt that they, and their lobbyists and specialist law firms (is there any daylight between them?) are pitching it to you to do exactly the opposite of what I submit here! It is so true, that ancient adage that stipulates that money begets money! But it’s also your job to prove that it could be untrue! Hard work begets a better quality of societal value! If you, the SEC, are here to ensure that our elected representatives (especially acting through appointed folk like you!) also serve us common folk, please ensure you consider the facts in all fairness, & get us a fair shake! Long have we been manipulated by the weighty and powerful, that it’s time to finally stand up, moral pitchforks of outrage to hand, and be counted. Please consider how the proposition also supports the ability of retail investors to better self vet and fully consider a would-be transaction, before handing over limited capital (compare to large funds and hedge funds that can cast millions into various vehicles). Consider how bigger players can find ways to contribute client capital they manage, while manipulating their trading actions; masking malafide intent under the cover of very bonafide trades! Our system ensures that these can never be tracked! So this is our proposition! We want to be able to “look (carefully and cautiously) before we leap”! This must surely appeal to the best instincts in terms of fairness, among you! You’re here to protect us! The SPAC in question, PSTH, also faces an obviously baseless (my personal view, based on simple uncommon sense) lawsuit, filed by an obviously serial litigant, a former commission member who has suddenly & inexplicably seen the light, after years of been party to legally vetting and approving numerous SPAC deals, and an unknown but Ivy league law faculty member. It only goes to show that in litigious US, anyone with malice aforethought, may so easily bring genuine processes of any human activity (including that of investment) to a rapid grinding halt, and given corrosive time value of money, to the resounding thud of financial disaster! One might say that the SEC cannot involve itself in matters sub judice, but it could nevertheless consider setting the record straight by engaging in separate regulatory actions that indirectly serve to comment on what is patently or morally wrong, and more to the point, bad in law! While the SPAC vehicle has given retail investors access to many early-stage high growth companies, the speculative nature of the vehicle along with sponsor promote has led to many unrealistic valuations. Such obvious venality is not true of the PSTH SPAC model! Approving SR-NYSE-2021-45 will alleviate many of these concerns while still granting retail investor access to either high-growth early-stage companies or mature revenue-generating companies. I also resolutely believe that such a rule change will further protect investors and further facilitate better financial information. Furthermore, it will enhance the reputation of US markets and its regulatory framework, to attract a spate of better class international companies from countries that are totally transparent & answerable to independent audit procedures (rather than those that are politically motivated!) to protect shareholders (especially minority shareholders!). Such actions will promote the value of their businesses on our trading floors, thereby adding value to the US and other investors like us, in general terms! IMHO, & yours truly AJ Jaganathan Owner Director Goodwin Montbeck Holdings Inc.