Subject: File Number SR-NYSE- 2019-67

Jun. 30, 2020


Good morning - First and foremost, I hope you and your families are safe and doing well during these chaotic times. 

I recently read that the NYSE has sent yet another proposal with re to Direct Listings and Primary Capital Raising for this alternate approach. I am still baffled how this is even a conversation. If the SEC were to approve this amendment, the capital markets, which is one of the few markets that is currently thriving, would come to a screeching halt. An amendment like this in such uncertain times would only create more uncertainty. The NYSE, who's stance should always be unbiased, has decided to align themselves with VC's and the private market. They know the only ones who benefit from this are the VC's and the stock exchange. If you look at who is leading the charge, Bill Gurley and Jay Ritter, you would see that they do not have the best intentions for everyone they claim they do. It's a vendetta against the Wall Street banks, which in my opinion, have done great at weathering the storm for their clients during the pandemic. Bill Gurley says he had an epiphany during the ETSY IPO because banks wouldn't alot him more stock. That means he turned a blind eye for over 2 decades of his career and now that he didn't get what he wanted, he decided to wage war against the Capital Markets. The only data he refers to is Jay Ritter's. But if you notice, Jay Ritter's data is completely skewed to fit their narrative. Any other expert weighing in clearly would oppose this ideology. They continue to discuss this IPO "pop" on the first day but is it really an artificial pop when companies continue to trade above those levels the days and months after the deal? In a Direct Listing, there have been 2 epic failures that they deem successes. Those successes may be for the private investors, but the retail and public investors who purchased stock in Spotify and Slack, were under water for years. It took a global pandemic for both stocks to get above their reference price. Look at some of the companies that would have completely misled investors if they did a Direct Listing. There would be a ton of lawsuits hitting your desk. There have been 2 well known Direct Listings and one company is already going through those lawsuits because of how Direct Listings are modeled. When investors start to see that Direct Listings do not work, liquidity will dry up immediately, all because a VC got his feelings hurt. I urge you to not pass this bill. It would be a detriment to our markets and will only continue to exacerbate the bifurcation of wealth. We do not need this change right now. Thank you for your time and feel free to reach out if need be. Please protect our markets from self-serving and radical ideas such as this one. 

Anonymous