Subject: S7-11-23: Webform Comments from Greg Linder
From: Greg Linder
Affiliation: Founder, Consulting Engineer, and SVP of Hardware Design

Aug. 20, 2023

In a world of High Frequency Trading and swap positions
being able to get moved back and forth between brokers at the speed of
electrons, it seems reasonable to me that the daily reserve
requirement calculations and margin-related calculations should be
operating as fast as reasonable possible.

Otherwise, every trade in the market of any kind becomes a sort of
large-scale time-based arbitrage, whereby the people owing the money
can just shift things in quickly to meet the weekly check, then move
it out again back into risky positions. A bit like a restaurant
proving their Pies are "fresh" by moving Fresh Pies into the
pie case in the morning, and then serving sloppy expired ones out the
back when no one is looking, only moving a Fresh Pie into the pie case
when eating a new customer.

The entire market seems rife with such efforts by large investors,
which serves to further move the market away from "lit and
reasonable" into "dark and obscure". If reserve
requirements aren't calculated in real time, in line with the
trades that depend on those reserve requirements as collateral, then
the entire market for such trades can present substantially more risk
than is made obvious in the weekly "checks" of such numbers.

Maybe in the 70's weekly checks were reasonable, when T+X
settlement type rules applied to everyone. But today, when trillions
of dollars flow between counter-party in time frames measured in
milliseconds or faster, it stands to reason that such reporting
requirements should also be made faster.