February 6, 2022
I strongly agree with the intent behind this proposal. I'm highly concerned with SWAPs being used as a vehicle for fraud and market manipulation. I'm in favor of mandating reporting of SWAP positions and implementing fines large enough to deter any misreporting as well as fines large enough to deter fraud and manipulation via SWAPs. It should also be recognized that reporting of SWAP positions should be mandatory for international as well as US funds, for any SWAPs that include US securities or derivatives.