Subject: S7-01-23: WebForm Comments from Florian Rhyn
From: Florian Rhyn
Affiliation:

Mar. 9, 2023

March 9, 2023

 Dear SEC

It is important that there are no exceptions or exemptions. This is exactly how market makers are able to make a business within the legalese. Their conflict of interest when operating as a market maker and hedge fund etc. under one umbrella has produced securities fraud that goes beyond Madoff.

Aside from such exemptions, I agree with the proposed rule.

Thank you for providing the opportunity to comment and thank you for listening to the people, not corporations.

Sincerely
Florian Rhyn


Quote, comment of Cory Siemon,  whom I absolutely agree with: \"Please remove all EXCEPTIONS from the proposal.
I realize that you have denied some exception requests, but this proposal still fails to protect investors much like most of the previous proposals because of catering to liquidity and market makers.

This is an excerpt from the SEC site clearly focused on allowing continued nefarious market making practices rather than focusing on regulation and future safety of pension funds.
\"The proposed rule would provide certain exceptions for risk-mitigating hedging activities, bona fide market-making activities, and certain commitments by a securitization participant to provide liquidity for the relevant ABS. The proposed exceptions would focus on distinguishing the characteristics of such activities from speculative trading. The proposed exceptions would also seek to avoid disrupting current liquidity commitment, market-making, and balance sheet management activities.\"

I'm sure many at the SEC are aware that market maker exemptions to regulations are the reason we have so much \"liquidity\" that security prices are detached from supply and demand fundamentals. It is the reason we have a majority of off lit exchange trading. It is the reason the public lost +20% of their life savings last year.
This proposal does little to reign in the market maker EXCEPTIONS and EXEMPTIONS posing the GREATEST RISK to our current and future financial markets.


As a broader scope, it appears as though the SEC is concerned that financial market values will come down if actual protective rules were passed and enforced. Regulatory Inaction, aka proposals full of EXCEPTIONS and EXEMPTIONS, is not an appropriate solution.
At the very least, please put into place regulations that apply to all market participants (including market makers) with multi-step time windows for compliance.

Yes, market security prices will shift as the opportunity to sell securities not actually in circulation is taken away.
It will likely upset current market makers who have enjoyed outstanding revenue streams by exploiting the ignorant American public and pension funds.
This will likely cause them to negatively impact near term pension values, given their control and impact over the security pricing.
But without regulating what have become extremely powerful market makers and just trying to work together, we've seen the results. I believe we are headed to a point of market liquidation or a market crash because trust is eroding and education is growing on market maker exploitation.

Congress mandated the SECs action causing this proposal. I expect and will do my best to continue causing congress to ask the SEC to improve your regulatory practices and proposals.
All of our financial futures depend on it. Please do not pretend we are addressing obvious market maker, hedge fund, and broker dealer conflicts of interest when the proposed regulation is full of EXCEPTIONS to their compliance.

Keep it simple. Keep it fair. Restore trust to our financial markets. Provide greater safety and stability to our pricing by prioritizing supply and demand over liquidity. It's not too late to do your job.\"