June 24, 2023
Dear SEC
As a household investor who has long been navigating the intricate world of finance, I wholeheartedly welcome the Securities and Exchange Commission's proposal for Rule 10B-1. This regulation, which mandates large trader position reporting for security-based swaps, appears to be a promising step towards enhancing transparency in our financial marketsa much-needed change for individual investors like myself. It gives everyone a clearer understanding of the securities landscape, allowing for better informed investment decisions and, ultimately, working towards leveling the playing field in a domain that often seems skewed in favor of large institutions.
As such, I urge the Commission to expedite its approval process for Rule 10B-1. Let's not slow-walk this necessary stride towards a fairer, more transparent marketit's high time we put the interests of everyday investors at the forefront.
a. The Reporting Threshold Amount should be lower if it requires the inclusion of the value of related securities owned by the holder of the security-based swap position. This would help ensure that all relevant financial exposures are taken into account and increase transparency about the risk profile of large traders.
b. Conversely, if the final rule does not require the inclusion of related securities in the calculation of the Reporting Threshold Amount, the threshold should be higher. This will prevent undue burden on traders whose security-based swap positions may not necessarily indicate a significant overall risk exposure.
c. The rule should allow for the offsetting of identical security-based swap positions. This could prevent over-reporting of positions that are effectively neutral in terms of risk exposure.
d. Consistent with the proposed rule, the final rule should require aggregation of security-based swap positions by any interconnected entities. This is important to avoid circumventing the reporting requirements through the division of positions among related entities.
e. f. If the rule does not require aggregation across legally separate entities (unless a guarantee exists), the threshold should be lower to prevent large positions from being obscured by being split across multiple entities.
g. If the final rule requires aggregation of positions established for ones own account and those established for others when sharing in economic risk or control, the threshold should be higher. This would acknowledge that these positions carry different levels of risk and responsibility for the reporting entity.
h. If the rule does not require the Reporting Threshold Amount to include positions entered into by an entity with a related entity, the threshold should be lower. This will ensure that risk exposure within interconnected entities remains transparent.
i. Depending on the combination of options, the Reporting Threshold Amount should be adjusted accordingly to ensure transparency and maintain a balance between regulatory oversight and the burden on reporting entities.
Regards