Aug. 28, 2021
Dear Sir/Madam, I'm writing in support of the proposed rule change for the listing of Subscription Warrants. (File Number: SR-NYSE-2021-45). This new and additional security in the form of the proposed Subscription Warrant (“SW”) will allow retail investors like myself to invest in promising and successful businesses that we otherwise would only have access to at a much later stage or at much higher valuations. The world needs to urgently leverage scientific breakthroughs, advances in technology, innovation in business models and human ingenuity to deal with the world’s most pressing issues such as climate change and wealth and income inequality. This new security will enable promising business and mature companies to raise capital efficiently and competitively, while spreading the upside and wealth to a larger class of retail investors. In my view, the SWs will herald a new cycle of sustainable economic growth and equitable distribution while addressing the limitations and disadvantages of the current IPO and SPAC vehicles for retail investors. IPOs have become a way for early-stage investors and underwriters to walk away with large exits at the expense of retail investors. Retail investors are not able to easily participate and share in the growth of such companies as they are listing much later than in the past. While the SPAC vehicle has given investors access to many early-stage high growth companies, the speculative element and lengthy capital lock-up with uncertain outcomes, and hefty sponsor promote fees has led to many unrealistic valuations, fraudulent misrepresntation and misaligned incentives. The SW overcomes various limitations and allows retail investors to: · Avoid locking up precious capital in a SPAC · Better vet and be comfortable or convinced of the merit and risks of the proposed business combination before investing · Removes the time constraints that risks SPAC sponsors cutting a good deal · Ensure the sponsor’s interests and incentives are aligned with the retail investors and target companies The proposed SW will also require rules and regulation. I hope the SEC will study and put these in place swiftly so that SR-NYSE-2021-45 can be approved in good time. As a retail investor, I look forward to the SEC continuing to foster innovation while protecting investors and facilitating capital formation and allocation. Thank you. Sincerely, Satinderpal Singh Sandhu