December 15, 2010
Regulation on reporting of "large traders" is firstly an ambiguous and subjective characteristic which may not necessarily be applicable to those who fall under the definition. Furthermore, this regulation brings about questions such as, "Do those who meet the criteria for a large trade on one occasion in a financial year have to adhere to these reporting rules indefinitely?" This could lead to the compilation of inaccurate and irrelevant data. In addition, there are additional costs the commission may be overlooking. For example, the cost of additional reporting for these broker-dealers. Moreover, large traders currently face order exposure problems which would intensify with the increased reporting they would be required to do, as they would subject themselves to potential misappropriation of identifying information because of their tax id number. Finally, this regulation contains components, such as the release of broker, account number and tax identification number, which implicates the commission in failing to protect non-public personal information. Thus, I believe this regulation is in need of modification to better suit the privacy of brokers, dealers, and large traders.