December 16, 2021
Thank you for allowing us to comment on this proposed rule change.
As a retail investor, I often feel like I have a stark disadvantage compared to the institutions that are also investing with/against me. We do not have the capital to make any measurable difference in any type of investment, while institutions have billions and billions of dollars that they can use to manipulate the market as they see fit.
As many people know, swaps are a financial instrument that tend to only benefit institutions and are ripe with dangers to the market. As we saw in 2008 with credit default swaps, to the current uses of swaps to hide the investments that institutions are making, often times leading to inaccurate reported data of securities in question.
Transparency in our financial markets is paramount to a free and fair market. It is obvious to me the swaps should be required reporting in the financial industry. I am highly in favor of this proposed rule change and strongly encourage its implementation as soon as possible.
My largest concern is that the thresholds for reporting are too high and that many companies will just split up and create a plethora of other companies to spread out their positions to continue the deceitful nation of many institutions. I strongly suggest updating this criteria to ensure loop holes are not created that allows institutions to avoid reporting their swaps. To me, it makes more sense to have institutions overreport than underreport.
Thank you for your time.