July 7, 2023
Dear SEC,
I am writing in regards to S7-32-10, Position Reporting of Security Based Swaps.
Response to requests for comment:
2a. I urge the SEC to institute a $0 threshold for security based swaps, to promote full and honest reporting. Swaps are complex, opaque, and constantly evolving. Having a minimum reporting requirement over $0 allows a possible avenue for obfuscation or outright fraud.
2b. Final ruling SHOULD include reporting of related securities by the swap holder.
2c. No, position off-set with identical short/long exposure should not obviate reporting requirements.
2d. Yes. Although this will be nearly impossible to enforce it is important to specify that swap parties acting in unison or including a \"shadow\" 3rd party are held to standard to report swap agreements.
Best,
Chance Furgerson