Subject: SR-NYSE-2021-45
From: Jack Holowczak
Affiliation:

Aug. 28, 2021

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To whom this may concern,


I am writing in support of SR-NYSE-2021-45. 


The approval of this rule change will benefit investors in the following ways:


1) De-risking of SPAC transactions by way of reducing or eliminating opportunity cost of committed capital while allowing for due diligence prior to committing capital. In this way, SPAC transactions may be structured for investors as "opt-in" as opposed to "opt-out", as they currently are. 


2) Sponsors/promoters become more aligned with the interests of their investors as subscription warrants would eliminate a great deal of upfront sponsor/promoter incentives.


3) Sponsors/promoters would not be subject to the same time constraints as traditional SPAC mergers. Poorly conceived or rushed mergers are disincentivized by the "opt-in" structure of subscription warrants. 


As a shareholder in PSTH (Pershing Square Tontine Holdings), it is obvious that the proposed SPARC (Special Purpose Acquisition Rights Company) which would be enabled by this rule change would mitigate/prevent harm to investors by providing a vehicle which offers the aforementioned benefits.  


I believe the approval of SR-NYSE-2021-45 would benefit investors immensely by providing greater protection to investors while encouraging the alignment of sponsors and investors in higher quality capital formation and business combinations.




Sincerely,


Jack Holowczak