Mar. 15, 2023
Good Afternoon, I am writing to you as a household investor who is very concerned with the current state of our markets. Let me be clear, I do not want any exceptions for risk-mitigating hedging activities, bona fide market making, and certain liquidity commitments. It is my understanding that the proposed rule exempts non-reporting companies from registering their certain securities offerings under the securities act, if they are exclusively sold to accredited investors. In my opinion as a household investor, this exemption has significant flaws. The proposed rule does not appropriately protect household investors like myself by reducing the information available, reducing the information available to households, and potentially lead to avoidable losses. . Transparency is king when it comes to our financial markets. I feel strongly that the proposed rule could be exploited by manipulative hedge funds and other excluded players. These funds and parties have a robust history of manipulative behavior in our securities markets. The exemption would offer yet another avenue and opportunity for these funds and players to engage in such practices to the detriment of our free markets. By limiting exemptions to accredited investors, hedge funds could, and I believe have demonstrated they would, create fake accredited investor accounts to conduct manipulative behavior outside of regulatory oversight to the detriment of our free markets. Please remember your mission to protect our free markets. As a household investor, I am trusting to you protect all players equally and promote free and transparent markets at every opportunity. Thank you for your time and consideration. Daniel Guiney Daniel Guiney President ZRM Brokerage, Inc. 980 Broadway, #550 Thornwood, NY 10594 914 450 9360 www.ZRMbrokerage.com