September 27, 2021
We are writing to support SR-NYSE-2021-45. Our firm has approximately $2B in assets under management and has been in business for 20 years. We have invested over $100 million in multiple SPACs over our history.
The new listing standard will, in our view, enhance a free, fair, and competitive market for all participants. We see the following specific merits to the proposal:
1) Investors will benefit from reduced opportunity cost and can hold onto their own cash while the sponsor searches for a deal.
2) Deal quality should improve as sponsors will be subject to less time pressure to close the deal given lower opportunity cost for investors.
3) The structure will afford greater protections to investors by allowing market participants to review the transaction before committing capital (opt-in vs. opt-out). Sponsors will need to make a complete and compelling case for why investors (retail and institutional) should write a check.
4) The proceeds of the warrants will be held in a custody account, which properly safeguards the capital.
5) The structure should increase and improve competition in SPAC markets and increase the fairness of the playing field for all investors.
Thank you for your time and consideration of our comments.
Locust Wood Capital